United States v. Iqbal, 684 F.3d 507 (5th Cir. 2012) (affirming district court order releasing portions of the presentence report from a criminal case to DHS for use in removal proceedings, because the reasons for confidentiality can be outweighed when [as here] the moving party can show a compelling, particularized need for disclosure to meet the ends of justice.); quoting United States v. Huckaby, 43 F.3d 135, 139 (5th Cir. 1995).

Note: Criminal defense counsel must therefore contest facts in the PSR that would prove damaging in later removal proceedings.