Sum v. Holder, ___ F.3d ___, 2010 WL 1630859 (9th Cir. Apr. 23, 2010) (aggravated felony bar to relief under INA 212(h) for lawful permanent residents is not defeated by claim that person was not "lawfully admitted" to permanent residence because he procured his green card by visa fraud.)

Vasquez v. Holder, 602 F.3d 1003 (9th Cir. Apr. 19, 2010) (hardship waiver, under INA 216(c)(4), to have condition removed for lawful permanent residents who did not jointly petition to remove conditions, or did not appear for an interview, is not available to a noncitizen who obtained LPR status though marriage fraud; however, noncitizen may seek relief under INA 237(a)(1)(H)).

Eneh v. Holder, 601 F.3d 943, 947 (9th Cir. Apr. 15, 2010) ("It is unclear whether the BIA adopted the IJ's reasoning in its entirety, affirmed on alternate grounds, added an additional ground for denying Eneh's claim, or simply misconstrued the IJ decision. Such ambiguity in the midst of the BIA's already limited analysis makes us unable to review the decision below in an adequate manner. See, e.g., Garcia Gomez v.

Matter of Alania-Martin, 25 I. & N. Dec. 231 (BIA Apr. 30, 2010) (noncitizens otherwise eligible to adjust status under INA 245(i) are not subject to the unauthorized employment restrictions of INA 245(c) and the exception in INA 245(k) that apply to applications for adjustment of status under section 245(a)).

Matter of Koljenovic, 25 I. & N. Dec. 219 (BIA Apr. 23, 2010) (noncitizen who adjusted status after having entered the United States without inspection has "previously been admitted to the United States as an alien lawfully admitted for permanent residence" and must therefore satisfy the 7-year continuous residence requirement of INA 212(h), 8 U.S.C. 1182(h) (2006), to be eligible for a waiver of inadmissibility).

Shabaj v. Holder, 602 F.3d 103 (2d Cir. Apr. 12, 2010) (noncitizen who entered with fraudulent Italian passport pursuant to Visa Waiver Program has waived right to removal proceedings, even where noncitizen was not Italian and not eligible for visa waiver program).

Sumbundu v. Holder, 602 F.3d 47 (2d Cir. Apr. 7, 2010) (failing to file tax return, or underrepresenting income, over a number of years constitutes a lack of good moral character under catchall provision of 8 U.S.C. 1101(f)).

Sumbundu v. Holder, 602 F.3d 47 (2d Cir. Apr. 7, 2010) (court has jurisdiction to review the DHS moral character determinations made pursuant to the catchall provision of 8 U.S.C. 1101(f), at least when the petitioners raise "constitutional claims or questions of law," 8 U.S.C. 1252(a)(2)(d)).

Bradley v. Attorney General of the U.S., 603 F.3d 235 (3d Cir. Apr. 22, 2010) (rejecting arguments that removal order is void under Woodby v. INS, 385 U.S. 276, 286 (1966), because the record lacks "clear, unequivocal, and convincing evidence" that noncitizen waived right to contest his removal under the Visa Waiver Program ("VWP"), 8 U.S.C.

Johnson v. United States Atty Gen., __ F.3d __ (3d Cir. Apr. 16, 2010) (court lacks jurisdiction to review discretionary determination on whether VAWA cancellation of removal applicant has shown that he suffered extreme cruelty inflicted by his spouse).