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Eleventh Circuit rejects Silva-Trevino: Sanchez Fajardo v. Atty. Gen.

"[W]e agree with the Third and Eighth Circuits that Congress unambiguously intended adjudicators to use the categorical and modified categorical approach to determine whether a person was convicted of a crime involving moral turpitude. ... [W]e hold that the BIA and the IJ erred by considering evidence...