Pagayon v. Holder, 642 F.3d 1226 (9th Cir. Jun. 24, 2011) (per curiam) (removal order was properly based, in part, on admissions petitioner made before the immigration judge: Pagayon's admission was needed only to confirm that the conviction was for the charged crime. . . . An IJ may consider an alien's admissions regarding removability if they are corroborated by the narrow, specified set of documents that are part of the record of conviction, Tokatly, 371 F.3d at 620. Absent some claim of mistake, duress or the like"which Pagayon does not raise"an admission is just as reliable as an explicit reference to the charging document in an abstract of judgment. And since an admission like Pagayon's does no more than establish that the conviction at issue was for the crime charged, it does not invite the IJ to improperly relitigate the criminal case by inquiring into the underlying facts of the crime.).
NOTE: In this case, the information indicated that the respondent was charged with possession of meth, but the abstract of judgment did not specify a controlled substance. The respondent's admission was only that he pleaded guilty as charged in the information. Therefore, he did not admit to any facts that were not already in the record of conviction.