State v. Yahya, 2011 Ohio 6090 (Ohio Ct. App. 2011) (claim of ineffective assistance of counsel brought pursuant to Padilla v. Kentucky, 130 S. Ct. 1473 (2010), was sufficiently meritorious to require an evidentiary hearing to determine whether a motion to withdraw a guilty plea should be granted: courts general advice about potential immigration consequences did not prevent a showing of prejudice from counsels incorrect advice); distinguishing State v. Yazici, 2011 Ohio 583 (Ohio App. Ct. 2011); State v. Ikharo, 2011 Ohio 2746 (Ohio App. Ct.

Cun-Lara v. State, 126 Hawai'i 541 (Hawaii App.

Matter of Sanchez Sosa, 25 I. & N. Dec. 807 (BIA Jun.

Matter of C. Valdez, 25 I&N Dec. 824 (BIA 2012) (noncitizen's pre-11/28/2009 admission to CNMI does not constitute inspection, admission, or parole in to the United States for purposes of adjustment of status under INA 245(a)).

Matter of Guzman-Martinez, 25 I&N Dec. 845 (BIA 2012) (an LPR may be treated as an applicant for admission, pursuant to INA 101(a)(13)(C)(iii), 8 U.S.C. 1101(a)(13)(C)(iii), if the DHS proves by clear and convincing evidence that the returning resident engaged in illegal activity at a United States port of entry; "illegal activity" is activity that is criminal; attempting to smuggle another into the United States constitutes criminal activity that occurred after departure from the United States and before re-admission).
http://www.justice.gov/eoir/vll/intdec/vol25/3759.pdf

Matter of C. Valdez, 25 I&N Dec. 824 (BIA 2012) (pre-November 28, 2009, admission to the Commonwealth of the Northern Mariana Islands (CNMI) by the CNMI Immigration Service does not constitute an inspection and admission or parole into the United States for purposes of adjustment of status pursuant to INA 245(a), 8 U.S.C. 1255(a) (2006)).
http://www.justice.gov/eoir/vll/intdec/vol25/3755.pdf

Matter of Isidro-Zamorano, 25 I&N Dec. 829 (BIA 2012) (applicant for cancellation of removal whose son or daughter met the definition of a "child" when the application was filed but turned 21 before the Immigration Judge adjudicated the application on the merits no longer has a qualifying relative under INA 240A(b)(1)(D), 8 U.S.C. 1229b(b)(1)(D) (2006); Child Status Protection Act does not apply to applications for relief); clarifying Matter of Bautista Gomez, 23 I&N Dec. 893 (BIA 2006).
http://www.justice.gov/eoir/vll/intdec/vol25/3756.pdf

Matter of Fernandez-Taveras, 25 I&N Dec.

Matter of Valenzuela Gallardo, 25 I&N Dec. 838 (BIA 2012) (California conviction of accessory after the fact, in violation of Penal Code 32, is an aggravated felony "obstruction of justice" offense if a sentence of one year or more is imposed on any single count).
http://www.justice.gov/eoir/vll/intdec/vol25/3758.pdf.

Vivieros v. Holder, ___ F.3d ___ (1st Cir. Jun. 25, 2012) (Massachusetts conviction of shoplifting, under Mass. Gen. Laws ch. 266, 30A, constituted a conviction for immigration purposes, under INA 101(a)(48)(A), 8 U.S.C. (a)(48)(A), where the defendant pleaded guilty and received a fine of $250, which was later vacated, so the ultimate disposition was a guilty finding with no fines or costs, because a formal judgment of guilt had been entered and the fine was not vacated on a ground of legal invalidity).

Note: This decision is mistaken.