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Farewell to Silva-Trevino: Olivas-Motta v. Holder

Carrie Rosenbaum writes: "Last week, the U.S. Court of Appeals for the Ninth Circuit rejected the Attorney General’s ruling that immigration courts can look beyond the record of conviction to determine if a conviction is a “crime involving moral turpitude.” See Olivas-Motta v....

CA9 on Clear Error: Zumel v. Lynch

"Assuming that intent under § 1182(a)(3)(B)(iii)(V)(b) is a factual question, the BIA here erred in failing to apply the clear error standard of review to the IJ’s resolution of the intent issue. ... Because the BIA did not acknowledge the proper standard of review, ignored facts found...