CA4 on Entry, Official Restraint: De Leon v. Holder

"[A] finding that De Leon entered free from official restraint would qualify him for cancellation of removal -- an outcome the government opposes.  The BIA cannot apply its official-restraint standard broadly when broadness favors the government’s position and narrowly when it does not. ... we grant the petition for review and remand the case to the BIA to consider De Leon’s application for NACARA relief in light of the proper legal standard." - De Leon v. Holder, July 30, 2014.  [Hats off to Cherylle Corpuz!]