Villanueva v. Holder, 784 F.3d 51, 54 (1st Cir. Apr. 24, 2015) (If those documents are inconclusive, then we must discard the modified categorical approach and determine whether all of the alternative means of committing the predicate crime fit within the federal definition of the generic offense.).

Lugo v. Holder, 783 F.3d 119 (2d Cir. Apr. 9, 2015) (remanding to BIA to determine whether to continue to adhere to Matter of Robles"Urrea, 24 I. & N. Dec. 22 (BIA 2006), holding that conviction of misprision of a felony, under 18 U.S.C. 4, is still a crime of moral turpitude in light of circuit split), citing Itani v. Ashcroft, 298 F.3d 1213, 1216 (11th Cir.2002), and Robles"Urrea v. Holder, 678 F.3d 702, 711 (9th Cir. 2012).

Lugo v. Holder, 783 F.3d 119 (2nd Cir. Apr.

Chavez-Alvarez v. Warden York County Prison, ___ F.3d ___, ___, 2015 WL 1567019 (3d Cir. Apr. 9, 2015) (granting habeas corpus and ordering prompt immigration bond hearing: we are convinced that, beginning sometime after the six-month timeframe considered by Demore, and certainly by the time Chavez"Alvarez had been detained for one year, the burdens to Chavez"Alvarez's liberties outweighed any justification for using presumptions to detain him without bond).

Hernandez v. Holder, 783 F.3d 189 (4th Cir. Apr. 14, 2015) (deferring to Matter of Cortez Canales, 25 I. & N. Dec. 301, 306"08 (2010), to find noncitizen barred from non-LPR cancellation of removal under INA 240A(b)(1), 8 U.S.C. 1229b(b)(1), due to being removable under INA 237(a)(2)(A)(i), 8 U.S.C. 1227(a)(2)(A)(i), even though the noncitizens only crime fits within the petty offense exception to inadmissibility).

Note: This is the first circuit court opinion to address Matter of Cortez.

Calix v. Lynch, 784 F.3d 1000 (5th Cir. Apr. 28, 2015) (lawful permanent resident seeking cancellation of removal who committed an offense that would make him or her inadmissible if actually seeking admission, within seven years of lawful admission, is barred from applying for cancellation of removal under the stop-time rule, INA 240A(d)(1)(B), 8 U.S.C. 1229b(d)(1)(B)).

Calix v. Lynch, 784 F.3d 1000, 1009 (5th Cir. Apr. 28, 2015) (Because we discover no holding to that effect, we find no grounds for deference under Chevron Step 2. An issue not discussed by an agency should not be seen as having implicitly been resolved in the way necessary to support the decision and the implication then be given deference.)

Corpuz v. Holder, 697 F.3d 807 (9th Cir. Aug. 31, 2012) (BIA improperly considered as the term of imprisonment the entire period noncitizen spent in psychiatric pre-trial civil confinement pending a determination of his competence to stand trial, to find noncitizen barred from relief under former INA 212(c)).

United States v. Marcia-Acosta, ___ F.3d ___ (9th Cir. Mar. 24, 2015) (Arizona conviction of aggravated assault, in violation of Arizona Revised Statutes 13-1203 and 13-1204, was not a "crime of violence" for illegal re-entry sentencing purposes; district court erred in relying solely upon a statement by defense counsel during plea colloquy in determining elements to which the defendant entered his plea, since a sentencing court may not rely on an extraneous factual-basis statement details, standing alone, to supply the narrowing for purposes of the modified categorical approach).

Rodriguez-Avalos v. Holder, __ F.3d __ (5th Cir. Mar. 4, 2015) (noncitizen cannot show 10 years good moral character prior to final administrative decision in non-LPR cancellation of removal application where noncitizen served 180 days or more in jail during such period).