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Immigration Law

CA2 on Retroactivity: Lauria v. Sessions (unpub.)

Lauria v. Sessions, Feb. 24, 2017 - "[W]ithout now deciding whether Vartelas identifies commission or conviction as the relevant date, but relying on the parties’ view that the matter may be decided by reference to commission, we remand for the agency to develop the record as to the date of commission of Lauria’s RICO crime of conviction. ... we GRANT the petition, VACATE the BIA’s judgment, and REMAND for further proceedings."

[Hats off to Thomas E. Moseley!]