Unlike circuit courts, where only an en banc decision can overrule a three-judge panel, a three-member panel of the Board can overrule any prior precedential decision. See, e.g., Matter of Alyazji, 25 I&N Dec. 397 (BIA 2011). Presumably, this is because a decision can only be designated as precedential following a vote in which it receives the support of a majority of permanent Board members. 8 CFR 1003.1(g). Thus, even when a decision only contains the names of three members, it has the support of a majority of the Board's permanent members. Thanks to Ben Winograd.