(E)  Withholding of Removal Requires Avoiding Aggregate Sentences of Five Years or More as a Result of Aggravated Felony Conviction(s).  Aggregate sentences for one or more aggravated felony convictions that total five years or more disqualify a noncitizen from receiving “restriction on removal,” formerly known as “withholding of deportation,” which protects them from deportation to a country in which life or freedom would be threatened because of race, religion, nationality, membership in a particular social group, or political opinion.  See § 10.72, infra.[280] 

 

[280] INA § § 241(b)(3)(A), (B), 8 U.S.C. § § 1251(b)(3)(A), (B).

SENTENCE - CONSECUTIVE SENTENCES
Oregon v. ICE, __ U.S. __, 129 S.Ct. 711 (Jan. 14, 2009) (Apprendi and Blakely, requiring jury to find sentencing factors that increase the maximum possible sentence do not apply to decisions whether to impose consecutive or concurrent sentences; the Sixth Amendment does not inhibit States from assigning to judges, rather than to juries, the finding of facts necessary to the imposition of consecutive, rather than concurrent, sentences).

Other

SENTENCE - SENTENCE IMPOSED - 12 MONTHS EQUALS ONE YEAR
12 months equals one year in immigration court. See Drakes v. Zimski, 240 F.3d 246, 251 (3d Cir. 2001); United States v. Christopher, 239 F.3d 1191, 1193 (11th Cir. 2001).