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Fourth Circuit on standard of review: Turkson v. Holder

January 27, 2012 (1 min read)

"The BIA erred in reviewing the IJ’s factual findings under the de novo standard of review instead of under the clearly erroneous standard prescribed by its governing regulations. We therefore grant Turkson’s petition for review, vacate the BIA’s decision, and remand for further proceedings consistent with this opinion." - Turkson v. Holder, Jan. 26, 2012.  [Hats off to Timothy W. Loose of the Los Angeles office of Gibson Dunn!]