Arca-Pineda v. Att'y Gen., 527 F.3d 101 (3d Cir. May 28, 2008) (respondent cannot re-start clock by failing to appear for removal proceeding and then waiting an additional 10 years).

Arca-Pineda v. Att'y Gen., 527 F.3d 101 (3d Cir. May 28, 2008) (continuous physical presence clock did not begin to run again after an administrative closure; administrative closure is not a termination proceedings; it only removes the case from the IJs calendar).

Arca-Pineda v. Att'y Gen., 527 F.3d 101 (3d Cir. May 28, 2008) (continuous physical presence clock did not begin to run again after an administrative closure; administrative closure is not a termination proceedings; it only removes the case from the IJs calendar).

United States v. Snellenberger, 548 F.3d 699 (9th Cir. Oct. 28, 2008) (per curiam) (en banc) (to determine the nature of a conviction, when applying the modified categorical approach of Taylor v. United States, 495 U.S. 575 (1990), the reviewing court may consider a clerk's minute order that conforms to certain essential procedures as establishing a plea to Count I, as opposed to Count II), overruling United States v. Diaz-Argueta, 447 F.3d 1167, 1169 (9th Cir. 2006).

FOR IMMEDIATE RELEASE: May 23, 2008
GOVERNOR PATERSON ANNOUNCES PARDON OF RICKY "SLICK RICK" WALTERS
On May 23, 2008, Governor David A. Paterson granted Ricky Walters a full and unconditional pardon of his 1991 attempted murder and weapon convictions, in order to allow Walters to seek relief from deportation from the federal immigration courts. "Mr.

Channer v. DHS Secretary, 527 F.3d 275 (2d Cir. May 30, 2008) (res judicata does not bar DHS from relitigating removal based on a claim which could have been raised in his previous removal proceeding where second removal proceeding did not involve the same claim or nucleus of operative fact as the first).

United States v. Chavarria-Brito, 526 F.3d 1184 (8th Cir. May 29, 2008) ("The mere fact that a state labels a crime as forgery does not control whether his crime is actually related to forgery [under federal law]."), citing Taylor v. United States, 495 U.S. 575, 590-591, 110 S.Ct. 2143, 109 L.Ed.2d 607 (1990).

Arca-Pineda v. Att'y Gen., 527 F.3d 101 (3d Cir. May 28, 2008) (retroactive application of the stop-time rule did not violate due process).

United States v. Bonilla, 524 F.3d 647 (5th Cir. Apr. 10, 2008) (sentencing court could not rely on a charge of which the defendant was not convicted to identify the particular subdivision, within a divisible statute, of which the defendant was convicted), citing United States v. Neri-Hernandes, 504 F.3d 587, 590 (5th Cir. 2007); see United States v. Gonzalez-Ramirez, 477 F.3d 310, 315 (5th Cir. 2007) (reaching same conclusion when defendant pleaded guilty to attempted kidnapping but indictment charged only aggravated kidnapping); see also United States v. Turner, 349 F.3d 833, 836 (5th Cir.

United States v. Bonilla, 524 F.3d 647 (5th Cir. Apr.