Cancellation of removal for non-lawful permanent residents[64] gives an immigration judge the discretion to “cancel the removal” of certain noncitizens who have resided illegally in the United States.  If cancellation is granted, the recipient is also given lawful permanent resident status.[65]  To be eligible for cancellation of removal, non-lawful permanent residents must:

 

(a)        have 10 years of continuous physical presence in the United States,[66]

(b)        establish Good Moral Character[67] during the preceding 10 years,[68]

(c)        show exceptional and extremely unusual hardship[69] to a United States citizen or LPR spouse, parent, or child, and

(d)        not have been convicted of an offense listed in INA § § 212(a)(2), 237(a)(2)[70] or (3), and not fall within the terrorism grounds of inadmissibility or deportability.[71]

 

This form of relief is unavailable to anyone deportable under any criminal ground or inadmissibility or deportability.  In the Ninth Circuit, certain non-LPRs with pre-April 1, 1997 or pre-November 29, 1990 convictions may still be eligible for former suspension of deportation relief.[72]

[64] INA § 240A(b), 8 U.S.C. § 1299b(b).

[65] There is an annual cap of 4,000 on these adjustments.  8 C.F.R. § 240A(e).

[66] See § 24.6, infra.  This ten-year period is calculated backwards from the date on which the application is finally resolved by the immigration court or BIA.  Matter of Ortega-Cabrera, 23 I. & N. Dec. 793 (BIA July 21, 2005).

[67] See § 15.6, supra.  See also INA § 101(f), 8 U.S.C. § 1101(f).

[68] The period during which good moral character must be established ends with the entry of a final administrative decision by the Immigration Judge or the Board of Immigration Appeals. Matter of Ortega-Cabrera, 23 I. & N. Dec. 793 (BIA July 21, 2005).  At least two courts have held that whether this requirement has been met is a question not subject to judicial review.  Lopez-Castellanos v. Gonzales, 437 F.3d 848 (9th Cir. Feb. 16, 2006) (court lacks jurisdiction to review IJ determination that respondent lacked good moral character required to be eligible for relief); Cuellar Lopez v. Gonzales, 427 F.3d 492 (7th Cir. Oct. 26, 2005).  Another has held that it is.  Jean v. Gonzales, 435 F.3d 475 (4th Cir. Jan. 27, 2006) (determination of whether non-LPR has good moral character for purposes of cancellation of removal is a non-discretionary factor subject to judicial review).

[69] Salvador-Calleros v. Ashcroft, 389 F.3d 959 (9th Cir. Nov. 23, 2004) (exceptional and extremely unusual hardship standard applied to non-LPR cancellation of removal does not violate due process as being overly strict).  At least two courts have found this to be a discretionary determination, not subject to judicial review. Martinez v. U.S. Att’y Gen., 441 F.3d 1219 (11th Cir. Apr. 21, 2006); Martinez-Maldonado v. Gonzales, 437 F.3d 679 (7th Cir. Feb. 10, 2006).

[70] This is true even though the noncitizens are subject to inadmissibility.  Gonzalez-Gonzalez v. Ashcroft, 390 F.3d 649 (9th Cir. Nov. 29, 2004) (inadmissible noncitizen who was convicted of a crime of domestic violence is also ineligible for cancellation of removal for non-LPRs under INA § 240A(b)(1)(C), 8 U.S.C. § 1229b(b)(1)(C)).  A waiver is available for certain noncitizens subject to domestic abuse.  See § 24.26(C), infra.

[71] See INA § § 240A(b)(1), (c), 8 U.S.C. § § 1229b(b)(1), (c).

[72] See § 24.24, infra.

BIA

RELIEF " CANCELLATION OF REMOVAL " QUALIFYING RELATIVE " AGE OUT
Matter of Isidro-Zamorano, 25 I&N Dec. 829 (BIA 2012) (applicant for cancellation of removal whose son or daughter met the definition of a "child" when the application was filed but turned 21 before the Immigration Judge adjudicated the application on the merits no longer has a qualifying relative under INA 240A(b)(1)(D), 8 U.S.C. 1229b(b)(1)(D) (2006); Child Status Protection Act does not apply to applications for relief); clarifying Matter of Bautista Gomez, 23 I&N Dec. 893 (BIA 2006). http://www.justice.gov/eoir/vll/intdec/vol25/3756.pdf

WAIVERS " CANCELLATION OF REMOVAL " EVIDENCE
Matter of Calderon-Hernandez, 25 I&N Dec. 885 (BIA 2012) (applicant for cancellation of removal seeking to establish exceptional and extremely unusual hardship to his or her child is not required to provide an affidavit and other documentary evidence regarding the childs care and support upon the aliens removal if the child will remain in the United States with another parent, even if the other parent is in this country unlawfully); clarifying Matter of Ige, 20 I&N Dec. 880 (BIA 1994).

RELIEF " CANCELLATION " STOP-TIME RULE " NOTICE TO APPEAR STOPS THE TIME EVEN IF IT DOES NOT GIVE A TIME OF HEARING
Matter of Camarillo, 25 I. & N. Dec. 644 (BIA Dec. 2, 2011) (any period of continuous residence or continuous physical presence of an alien applying for cancellation of removal under section INA 240A is deemed to end upon the service of a notice to appear on the alien, even if the notice to appear does not include the date and time of the initial hearing). http://www.justice.gov/eoir/vll/intdec/vol25/3734.pdf

RELIEF - NON-LPR CANCELLATION OF REMOVAL - CRIMES OF MORAL TURPITUDE - PETTY OFFENSE EXCEPTION
Matter of Cortez, 25 I. & N. Dec. 301 (BIA Aug. 13, 2010) (an alien who has been convicted of a crime involving moral turpitude for which a sentence of a year or longer may be imposed has been convicted of an offense "described under" INA 237(a)(2), and is therefore ineligible for non-LPR cancellation under INA 240A(b)(1)(C), regardless of whether the noncitizen qualifies for the petty offense exception under INA 212(a)(2)(A)(ii)(II)), clarifying Matter of Almanza, 24 I. & N. Dec. 771 (BIA 2009), explaining Matter of Gonzalez-Zoquiapan, 24 I. & N. Dec. 549 (BIA 2008); Matter of Gonzalez-Silva, 24 I. & N. Dec. 218 (BIA 2007); and Matter of Garcia-Hernandez, 23 I. & N. Dec. 590 (BIA 2003).

RELIEF - ADUSTMENT OF STATUS - EMPLOYMENT RESTRICTIONS
Matter of Alania-Martin, 25 I. & N. Dec. 231 (BIA Apr. 30, 2010) (noncitizens otherwise eligible to adjust status under INA 245(i) are not subject to the unauthorized employment restrictions of INA 245(c) and the exception in INA 245(k) that apply to applications for adjustment of status under section 245(a)).

RELIEF - NON-LPR CANCELLATION OF REMOVAL - CRIMES OF MORAL TURPITUDE - PETTY OFFENSE EXCEPTION
Matter of Pedroza, 25 I. & N. Dec. 312 (BIA 2010) (conviction for crime involving moral turpitude does not render noncitizen ineligible for cancellation of removal under INA 240A(b)(1)(C), if his crime is punishable by imprisonment for a period of less than a year and qualifies for the petty offense exception under INA 212(a)(2)(A)(ii)(II)), following Matter of Cortez, 25 I. & N. Dec. 301 (BIA 2010).

RELIEF " TEMPORARY PROTECTED STATUS " TPS
Matter of Sosa, 25 I. & N. Dec. 391 (BIA 2010) (a grant of Temporary Protected Status waives certain grounds of inadmissibility or deportability solely for the limited purpose of permitting an alien to remain and work temporarily in the United States for the period of time that TPS is effective, but it is not proper to terminate an aliens removal proceedings based on a grant of TPS). http://www.justice.gov/eoir/vll/intdec/vol25/3702.pdf

RELIEF - CANCELLATION OF REMOVAL FOR NON-LPRS - NONCITIZEN CONVICTED OF CMT IS INELIGIBLE REGARDLESS OF PETTY OFFENSE EXCEPTION
Matter of Gabriel Almanza-Arenas, 24 I. & N. Dec. 771 (BIA, Apr. 13,2009) (noncitizen who has been convicted of a crime involving moral turpitude has been "convicted of an offense under" INA 237(a)(2), 8 U.S.C. 1227(a)(2)(2006), and is therefore ineligible for cancellation of removal under INA 240A(b)(1)(C), regardless of his status as an arriving alien or his eligibility for a petty offense exception under INA 212(a)(2)(A)(ii)(II), 8 U.S.C. 1182(a)(2)(A)(ii)(II)).

NOTE: This is a bad decision, contrary to earlier BIA precedent. Counsel should argue that this case applies only within the Ninth Circuit, as it relies upon a Ninth Circuit decision from 2004. Gonzalez-Gonzalez v. Ashcroft, 390 F.3d 649 (9th Cir. 2004) found that the plain language of 240A(b)(1)(C) required a noncitizen in inadmissibility proceedings be denied non-LPR cancellation because hed been convicted of a DV offense. This holding was based upon the "plain language" of the statute, thus no Chevron deference owed to the BIA cases to the contrary.

Under Matter of Garcia-Hernandez, such a person is not ineligible because the petty offense exception of 212(a) is incorporated into the moral character and specified offense bars of 240A(b)(1)(c) . This was recently reaffirmed in Matter of Gonzalez-Zoquiapan, 24 I&N Dec. 549, 554 (BIA 2008).

The BIA didnt address whether Almanza-Arenas had committed the CMT more than five years after his entry into the U.S. Arguably (see Moran v. Ashcroft, 395 F.3d 1089 (9th Cir. 2005)), a noncitizen with a CMT conviction is still ok if the offense falls within the petty offense exception AND was committed more than five years after entry to the U.S. INA 237(a)(2)(A)(i). Gonzalez v. Gonzalez didnt address the issue that a DV offense must be committed after admission to trigger removal. Counsel can argue that for purposes of 240A(b), the "admission" language is (somehow) deemed irrelevant in light of Gonzalez-Gonzalez, but the rest of the 237 language remains, including the five year requirement to trigger removal.

RELIEF - NON-LPR CANCELLATION - CONTINUOUS PRESENCE
Matter of Cisneros-Gonzalez, 23 I. & N. Dec. 668 (BIA 2004) (noncitizen who departs the U.S. after being served a charging document in a prior proceeding can, upon deportation and subsequent illegal re-entry, accrue another period of continuous physical presence for eligibility for non-LPR cancellation of removal).

RELIEF - CANCELLATION OF REMOVAL FOR NON-LPRS - QUALIFYING RELATIVE INCLUDES STEPPARENT
Matter of Morales, 25 I. & N. Dec. 186 (BIA Jan. 27, 2010) (stepparent who qualifies as a "parent" under INA 101(b)(2), 8 U.S.C. 1101(b)(2) (2006), at the time of the proceedings is a qualifying relative for purposes of establishing exceptional and extremely unusual hardship for cancellation of removal under INA 240A(b)(1)(D), 8 U.S.C. 1229b(b)(1)(D)(2006)).

RELIEF - CANCELLATION OF REMOVAL FOR NON-LPRS
Practice Advisory on Matter of Almanza-Arenas, Non-LPR Cancellation and Moral Turpitude: Vasquez-Hernandez Does Not Hurt the Cause in the Ninth Circuit, by Kathy Brady, ILRC, http://www.ilrc.org/immigration_law/pdf/DOC%20vasquez%20hernandez%20practice%20advisory%201.pdf

First Circuit

RELIEF " NON-LPR CANCELLATION OF REMOVAL " BURDEN OF PROOF
Peralta Sauceda v. Lynch, 804 F.3d 101 (1st Cir. Oct. 14, 2015) (noncitizen had burden of proof by a preponderance of the evidence to establish he had not been convicted of a crime of domestic violence, even though Maine courts do not maintain records sufficient to show whether he was convicted under the bodily injury prong of the Maine statute, rather than the general assault prong, which does not involve sufficient violence). NOTE: This case has been reversed on rehearing by Peralta Sauceda v. Lynch, __ F.3d __ (1st Cir. Apr. 22, 2016) (whether a noncitizen is barred from relief is due to a conviction under a divisible statute is a question of law, and therefore not subject to a determination of who bears the burden of proof).

RELIEF " NON-LPR CANCELLATION OF REMOVAL " EXCEPTIONAL AND EXTREMELY UNUSUAL HARDSHIP STANDARD
Alvarado v. Holder, 743 F.3d 271 (1st Cir. Feb. 14, 2014) (IJ applied appropriate exceptional and extremely unusual hardship standard for non-LPR cancellation, under INA 240A(b)(1)(D), 8 U.S.C. 1229b(b)(1)(D), in finding that respondents gifted childs heightened educational needs did not establish sufficient hardship to grant relief).

RELIEF " CANCELLATION " STOP-TIME RULE
Soto v. Holder, 736 F.3d 1009 (1st Cir. Dec. 3, 2013) (clock for purposes of stop-time rule for cancellation of removal ended on date NTA was served on the noncitizen, even though it was not served on the Immigration Court until two years later).

RELIEF " CANCELLATION OF REMOVAL " NON-LPR CANCELLATION " GOOD MORAL CHARACTER " STATUTORY BARS " JUDICIAL REVIEW
Reynoso v. Holder, ___ F.2d ___, 2013 WL 1197744 (1st Cir. Mar. 26, 2013) (whether applicant for non-LPR cancellation is barred from showing good moral character, under INA 101(f), 8 U.S.C. 1101(f), is a legal question open to judicial review).

RELIEF " CANCELLATION OF REMOVAL " GOOD MORAL CHARACTER " CREDIBILITY
Restrepo v. Holder, 676 F.3d 10 (1st Cir. Apr. 12, 2012) (substantial evidence in the record established that petitioner provided false testimony under oath at his immigration hearings regarding the motives underlying his divorce, so he was statutorily precluded from obtaining cancellation of removal relief because he lacked good moral character).

RELIEF - CANCELLATION - CONTINUOUS PRESENCE REQUIREMENT
Acevedo-Aguilar v. Gonzales, 517 F.3d 8 (1st Cir. Feb. 15, 2008) (noncitizen bears burden of establishing continuous presence for non-LPR cancellation purposes, including proving lack of absence from the United States for more than 90 days).

Second Circuit

RELIEF - NON-LPR CANCELLATION OF REMOVAL
Mendez v. Holder, 566 F.3d 316 (2d Cir. May 8, 2009) (BIA made legal error by overlooking and mischaracterizing medical facts relevant to determination of exceptional and extremely unusual hardship standard for non-LPR cancellation of removal)

Third Circuit

RELIEF " NON-LPR CANCELLATION OF REMOVAL " CONVICTION BAR
Castillo v. Holder, 729 F.3d 296 (3d Cir. 2013) (state judicial disposition must be a conviction under INA 101(a)(48), , 8 U.S.C. 1101(a)(48), in order to trigger the criminal conviction bar to non-LPR cancellation of removal).

RELIEF " CANCELLATION OF REMOVAL
Pareja v. U.S. Attorney General, __ F.3d __ (3d Cir. Jul. 29, 2010) (BIAs interpretation of the exceptional and extremely unusual hardship standard deserves deference under Chevron; remanding to the BIA to clarify application of Matter of Recinas, 23 I. & N. Dec. 467 (BIA 2002), where BIA distinguished the current case by noting a difference in the number of qualifying relatives " an impermissible factor under 8 U.S.C. 1229b(b)(1)(D)).

Fifth Circuit

RELIEF " CANCELLATION OF REMOVAL FOR NON-LPRS " MULTIPLE OFFENSES WITH TOTAL SENTENCES OF FIVE YEARS OR MORE
Pina-Galindo v. Lynch, 803 F.3d 193 (5th Cir. Sept. 24, 2015) (per curiam) (non-LPR cancellation criminal bar includes inadmissibility INA 212(a)(2)(B), 8 U.S.C. 1182(a)(2)(B) [multiple convictions with sentences totaling five years or more]).

RELIEF " NON-LPR CANCELLATION OF REMOVAL " CRIME OF MORAL TURPITUDE CONVICTION BAR
Nino v. Holder, 690 F.3d 691 (5th Cir. Aug. 13, 2012) (for purposes of determining whether an applicant is ineligible for cancellation of removal for nonpermanent residents pursuant to INA 240A(b)(1), 8 U.S.C. 1229b(b)(1), it does not matter when the crime of moral turpitude occurred in relation to the alien's admission), following the reasoning of Matter of Cortez, 25 I&N Dec. 301 (BIA 2010).

Sixth Circuit

RELIEF " NON-LPR CANCELLATION OF REMOVAL " HARDSHIP
Montanez-Gonzales v. Holder, __ F.3d __ (6th Cir. Mar. 12, 2015) (rejecting constitutional challenges to Immigration Judges standards in determining exceptional and extremely unusual hardship for non-LPR cancellation of removal).

Seventh Circuit

RELIEF " WAIVERS " NON-LPR CANCELLATION OF REMOVAL " CONVICTION OF CRIME OF MORAL TURPITUDE
Coyomani-Cielo v. Holder, ___ F.3d ___, 2014 WL 3401248 (7th Cir. Jul. 14, 2014) (BIA reasonably interpreted ambiguous statute, INA 240A(b)(1)(C), 8 U.S.C. 1229b(b)(1)(C), to mean that noncitizen convicted of crime of moral turpitude was ineligible for cancellation of removal for non-LPRs, even though conviction fit within petty offense exception to inadmissibility, since noncitizen could be found deportable for a single CMT), deferring to BIA decision in Matter of Cortez, 25 I. & N. Dec. 301 (BIA 2010).

RELIEF " WAIVERS " CANCELLATION OF REMOVAL FOR NON-LPRS " A CONVICTION UNDER INA 212(a)(2) BARS CANCELLATION DESPITE ELIGIBILITY FOR A WAIVER UNDER INA 212(h)
Barma v. Holder, ___ F.3d ___, 2011 WL 1237608 (7th Cir. Apr. 5, 2011) (a controlled substances conviction bars cancellation of removal for non-permanent residents, even though respondent is eligible for a waiver of inadmissibility under INA 212(h), because the bar under INA 240A(b)(1)(C) does not refer to 1182 as a whole, but rather refers to one distinct subsection, 1182(a)(2); nothing in that subsection incorporates the waiver provision in 1182(h): There is no reason to believe that other provisions of the inadmissibility statutory provision were incorporated into the cancellation of removal provision, and such an interpretation is inconsistent with a plain language reading.).

RELIEF " CANCELLATION OF REMOVAL " HARDSHIP " JUDICIAL REVIEW
Champion v. Holder, 626 F.3d 952 (7th Cir. Nov. 22, 2010) (court has jurisdiction to review whether the Immigration Judge and BIA took sufficient notice of facts relevant in determining hardship for purposes of non-LPR cancellation of removal).

Eighth Circuit

RELIEF - CANCELLATION OF REMOVAL FOR NON-LPRS - CONTINUOUS RESIDENCE - CORROBORATION REQUIRED
Sanchez-Velasco v. Holder, 593 F.3d 733 (8th Cir. Jan. 20, 2010) (noncitizen failed to provide reasonably available corroborative evidence of 10 years presence; court found noncitizen had failed to present reasonably available corroborating evidence because parents who lived in the U.S. without documentation would not testify for fear of being placed in removal proceedings).

RELIEF - NON-LPR CANCELLATION - HARDSHIP
Vargas v. Holder, 567 F.3d 387 (8th Cir. May 20, 2009) (BIA did not abuse discretion in denying motion to reopen based on fact that respondents daughter had been involved in a serious car accident where daughter was neither a USC or LPR child, and therefore was not a person for whom hardship could be shown).

Ninth Circuit

RELIEF - NON-LPR CANCELLATION OF REMOVAL
Partap v. Holder, 603 F.3d 1173 (9th Cir. May 10, 2010) (noncitizens unborn daughter did not meet statutory definition of "child" under 8 U.S.C. 1101(b)(1) for purposes of qualifying for cancellation of removal for non-lawful permanent residents).

RELIEF - CANCELLATION FOR NON-LPRS - PETTY OFFENSE EXCEPTION
Vasquez-Hernandez v. Holder, 590 F.3d 1053,1055 n.2 (9th Cir. Jan. 6, 2010) (leaving open the question of whether an applicant for non-LPR cancellation of removal, who has a conviction that fits within the petty offense exception to inadmissibility, under INA 212(a)(2)(A)(ii)(II), is barred from cancellation of removal because of the conviction, where the "offense" of conviction is not described by any non-CMT grounds of deportation).

RELIEF - CANCELLATION FOR NON-LPRS - PETTY OFFENSE EXCEPTION
Vasquez-Hernandez v. Holder, 590 F.3d 1053 (9th Cir. Jan. 6, 2010) (California conviction of corporal injury of a spouse, in violation of Penal Code 273.5(a), which fit within the petty offense exception to inadmissibility, nonetheless disqualified respondent from eligibility for cancellation of removal for non-LPRs, under INA 240A(b), because the same offense could have been grounds for deportation as a crime of domestic violence, under INA 237(a)(2)(E)(i), 8 U.S.C. 1227(a)(2)(E)(i)).

RELIEF - NON-LPR CANCELLATION - HARDSHIP
Mendez-Castro v. Mukasey, 552 F.3d 975 (9th Cir. Jan. 12, 2009) (court lacks jurisdiction to review IJs determination of whether respondents established exceptional and extremely unusual hardship to a child who had been in special education for speech development, but was showing improvement, and another child who was an honors student in English, but had no knowledge of Spanish).

RELIEF - NON-LPR CANCELLATION
Figueroa v. Mukasey, 543 F.3d 487 (9th Cir. Sept. 10, 2008) (IJ applied wrong standard in requiring that deportation would result in unconscionable harm to noncitizens children; IJ also erred by looking only at present harm to children, and failed to considered future harm). See also, Matter of Monreal-Aguinaga, 23 I. & N. Dec. 56, 61 (BIA 2001) (en banc) ("[W]e do not find that an unconscionable standard is an appropriate one to apply in evaluating a respondent's eligibility for cancellation of removal under section 240A(b) of the Act."); Matter of Recinas, 23 I. & N. Dec. 467, 468 (BIA 2002) ("We specifically stated ... that the alien need not show that such hardship would be unconscionable. ").

RELIEF - NON-LPR CANCELLATION OF REMOVAL - CRIMINAL BARS
Flores-Juarez v. Mukasey, 530 F.3d 1020 (9th Cir. Jun. 26, 2008) (the bar to non-LPR cancellation of removal for noncitizens who fall within certain criminal grounds of removal, under INA 240A(b)(C), applies regardless of the date of the conviction; the 10-year Good Moral Character requirement under INA 240A(b)(B) does not also impose a 10 year limit on the period in which the criminal convictions must have occurred).

RELIEF - NON-LPR CANCELLATION OF REMOVAL - PHYSICAL PRESENCE REQUIREMENT
Landin-Zavala v. Gonzales, 488 F.3d 1150, 2007 WL 1518854 (9th Cir. May 25, 2007) (order of excludability, acceptance of voluntary departure, and subsequent deportation stop the accrual of physical presence required to become eligible for non-LPR cancellation of removal).

RELIEF - NON-LPR CANCELLATION OF REMOVAL - PHYSICAL PRESENCE REQUIREMENT
Landin-Zavala v. Gonzales, 488 F.3d 1150 (9th Cir. May 25, 2007) (order of excludability, acceptance of voluntary departure, and subsequent deportation stop the accrual of physical presence required to become eligible for non-LPR cancellation of removal).

RELIEF - CANCELLATION OF REMOVAL - HARDSHIP
Montero-Martinez v. Ashcroft, 277 F.3d 1137, 1144-45 (9th Cir. 2002) (an adult son or daughter over 21 does not qualify as a "child" for purposes of showing exceptional and extremely unusual hardship to a spouse, parent or child).

RELIEF - NON-LPR CANCELATION - HARDSHIP
Rendon v. Holder, __ F.3d __ (9th Cir. Dec. 2, 2009) (Immigration Judge denied respondent a full and fair hearing by unreasonably limiting her testimony and denying her request for a continuance).

Tenth Circuit

RELIEF " NON-LPR CANCELLATION OF REMOVAL " PETTY OFFENSE EXCEPTION
Lucio-Rayos v. Sessions, 875 F.3d 573 (10th Cir. Nov. 14, 2017)(assumed moral turpitude conviction disqualified respondent from eligibility for discretionary cancellation of removal, and qualifying for the petty offense exception to moral turpitude inadmissibility would not change this result); following In re Cortez Canales, 25 I&N Dec. 301, 303-04 (BIA 2010); see also Mancilla-Delafuente v. Lynch, 804 F.3d 1262, 1265-66 (9th Cir. 2015); Hernandez v. Holder, 783 F.3d 189, 191-96 (4th Cir. 2015).

Other

RELIEF - CANCELLATION OF REMOVAL FOR NON-LPRS
Practice Advisory on Matter of Almanza-Arenas, Non-LPR Cancellation and Moral Turpitude: Vasquez-Hernandez Does Not Hurt the Cause in the Ninth Circuit, by Kathy Brady, ILRC, http://www.ilrc.org/immigration_law/pdf/DOC%20vasquez%20hernandez%20practice%20advisory%201.pdf LINKS - FEDERAL DEFENDER PUBLICATIONS Fd.org is also a great source of info -- links to various of their publications: http://fd.org/odstb_publications.htm