Matter of Chavez-Alvarez, 26 I. & N. Dec. 274 (BIA Mar. 14, 2014) (an sentencing enhancement element listed in a specification in the Manual for Courts-Martial, that must be pled and proved beyond a reasonable doubt, is the functional equivalent of an element of a criminal offense for immigration purposes).

Matter of C-J-H, 26 I. & N. Dec. 284 (BIA 2014) (noncitizen who has already adjusted status from asylee to LPR cannot re-adjust under INA 209(b), as a defense to removal).

Matter of Islam, 25 I&N Dec. 637, 643 (BIA 2011) (very restrictive interpretation of single scheme exception for multiple moral turpitude conviction ground of deportability, calling into question the authority of older cases with a more generous interpretation: the BIA cited to Chevron and Brand X and concluded: "We respectfully conclude that our analysis there is controlling and should now be uniformly applied in all circuits throughout the country.").

Note: There is a good argument, however, to the contrary. E.g., Gonzalez-Sandoval v. U.S. INS, 910 F.2d 614 (9th Cir.

Matter of Chavez-Alvarez, 26 I. & N. Dec. 274 (BIA Mar. 14, 2014) (adjustment of status constitutes an admission for purposes of determining removability under INA 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii), as an alien convicted of an aggravated felony at any time after admission).

Castillo v. Holder, 729 F.3d 296 (3d Cir. 2013) (state judicial disposition must be a conviction under INA 101(a)(48), , 8 U.S.C. 1101(a)(48), in order to trigger the criminal conviction bar to non-LPR cancellation of removal).

Miresles-Zuniga v. Holder, 743 F.3d 110 (5th Cir. Feb. 14, 2014) (stop time rules requirement that offense must be referred to in INA 212(a)(2), does not mean that the stop-time rule is met only if a comparable ground of deportation is triggered; respondent was barred from cancellation of removal where conviction was a CMT, triggering inadmissibility, and a domestic violence offense triggering deportability, even though the offense did not trigger deportability as a CMT).

Sarmientos v. Holder, 742 F.3d 624 (5th Cir. Feb. 12, 2014) (We may not affirm the BIA's decision except on the basis of the reasons it provided.); quoting Rodriguez"Barajas v. Holder, 624 F.3d 678, 679 (5th Cir. 2010).

Siwe v. Holder, 742 F.3d 603 (5th Cir. Feb. 6, 2014) (an alien whose asylum has been terminated is not prohibited from applying for adjustment of status).

Tadevosyan v. Holder, 743 F.3d 1250 (9th Cir. Feb. 26, 2014) (BIA abused its discretion by according controlling weight to fact of DHS opposition to motion to reopen, without analyzing whether DHS was correct).

Tadevosyan v. Holder, 743 F.3d 1250 (9th Cir. Feb. 26, 2014) (granting petition for review because BIA failed to provide any reasoned explanation for its decision).