Matter of Jurado-Delgado, 24 I. & N. Dec. 29 (BIA Sept. 28, 2006) (commission of offense stops the clock for cancellation of removal, by terminating a period of continuous residence in the United States pursuant to INA 240A(d)(1)(B), even though the offense was not charged as nor found to be a ground of inadmissibility or deportability), distinguishing Matter of Fortiz, 21 I. & N. Dec. 1199 (BIA 1998); see also Salviejo-Fernandez v. Gonzales, 455 F.3d 1063 (9th Cir. 2006) (rejecting due process challenge to use of uncharged conviction to find a noncitizen ineligible for relief).
jurisdiction:
BIA