Makir-Marwil v. Atty' Gen., 681 F.3d 1227 (11th Cir. May 22, 2012) (Matter of Jean standard for "violent or dangerous" crimes may be determined by either a categorical or factual analysis of the offense; IJ and BIA erred in failing to consider individual hardship, including country conditions, in determining that applicant would suffer exceptional and extremely unusual hardship).