Ali v. U.S. Attorney General, ___ F.3d ___, 2006 WL 709870 (7th Cir. Mar. 22, 2006) (per curiam) (Georgia conviction of two counts of child molestation, followed by the granting of an extraordinary motion for a new trial, and the State of Georgia's motion to nolle prosse charges, continued to constitute a conviction under INA 101(a)(48)(A), 8 U.S.C. 1101(a)(48)(A), for removal purposes, since noncitizen failed to establish that conviction had been vacated based on a procedural or substantive defect in the underlying criminal proceedings; noncitizen bears burden to show conviction was vacated on a basis of legal invalidity). This decision violates the long-standing rule that the government bears the burden of establishing by clear and convincing evidence every fact necessary to prove deportability. Woodby v. INS, 385 U.S. 276 (1966).