11/13/2012 03:02:00 PM EST
BIA Applies Brand X: Matter of M-H-, ID3772
The holding in Matter of N-A-M-, 24 I&N Dec. 336 (BIA 2007), that an offense need not be an aggravated felony to be considered a particularly serious crime for purposes of barring asylum or withholding of removal, should be applied to cases within the jurisdiction of the United States Court of Appeals for the Third Circuit. - Matter of M-H-, Int. Dec. 3772, 26 I&N Dec. 46 (BIA 2012)