Tooby's California Post-Conviction Relief for Immigrants

(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 § 8.15, infra.[15] 

[15] 8 U.S.C. § 1231(b)(3)(A), (B).