Matter of Pagan-Sis 27 I&N Dec. 130 (BIA 2017) (noncitizen seeking waiver under INA 212(a)(6)(A)(ii) must satisfy all three subclauses of that section, including the requirement that the noncitizen be a VAWA self-petitioner).

Lowe v. Sessions, 872 F.3d 713 (5th Cir. Oct. 5, 2017) (noncitizen waived claim of ineffective assistance of counsel by failing to brief the issue on appeal to the BIA).

Garcia v. Sessions, __ F.3d __ (7th Cir. Oct. 11, 2017) (noncitizen subject to reinstatement of removal is barred by INA 241(a)(5) from applying for asylum).

Asentic v. Sessions, 873 F.3d 974 (7th Cir. Oct. 17, 2017) (court lacks jurisdiction to review discretionary denial of fraud waiver under INA 237(a)(1)(H)).

Villegas-Sarabia v. Sessions, 874 F.3d 871 (5th Cir. Oct. 31, 2017) (federal conviction of misprision of a felony, in violation of 18 U.S.C. 4 ((1) knowledge that a felony was committed; (2) failure to notify the authorities of the felony; and (3) an affirmative step to conceal the felony."), was a crime against moral turpitude, because misprision of a felony required an intentional act of deceit); following Patel v. Mukasey, 526 F.3d 800 (5th Cir. April 29, 2008); Itani v. Ashcroft, 298 F.3d 1213, 1216 (11th Cir.

Saldivar v. Sessions, 877 F.3d 812 (9th Cir. Nov.

Lucio-Rayos v. Sessions, 875 F.3d 573 (10th Cir. Nov. 14, 2017) (conviction under Westminster, Colo., Municipal Code 6-3-1(A) did not categorically qualify as a crime involving moral turpitude because the statute was divisible, since one portion of the statute " demanding consideration for return of property " did not involve a permanent taking; because it was unclear from the record of conviction whether he committed a CIMT, he did not sustain his burden to prove eligibility for cancellation of removal).

NOTE: The court found that Matter of Diaz-Lizarraga, 26 I. & N. Dec.

(BIA reasonably concluded INA 212(h) cannot be used to waive CMT bar to applicants seeking relief under INA 240A(b)(2)(A), VAWA cancellation).

Matter of Vella, 27 I&N Dec.

Matter of Tavdidishvili, 27 I&N Dec. 142 (BIA 2017) (New York conviction of negligent homicide, in violation of New York Penal Law 125.10, is categorically not a crime involving moral turpitude, because it does not require that a perpetrator have any awareness of the facts that make his or her conduct dangerous.).