Criminal Defense of Immigrants
§ 23.21 (E)
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(E) National Security. Any noncitizen who “has engaged, is engaged, or at any time after admission engages in” any other criminal activity which endangers public safety or national security. NOTE: No conviction is required to establish this ground of deportation.
 INA § 237(a)(4)(A)(ii), 8 U.S.C. § 1227(a)(4)(A)(ii).