Carachuri-Rosendo v. Holder, 130 S.Ct 2577 (Jun. 14, 2010) ("Finally, as we noted in Leocal v. Ashcroft, 543 U.S. 1, 11 n. 8, 125 S.Ct. 377, 160 L.Ed.2d 271 (2004), ambiguities in criminal statutes referenced in immigration laws should be construed in the noncitizen's favor. And here the critical language appears in a criminal statute, 18 U.S.C. 924(c)(2).")