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.

Vivieros v. Holder, ___ F.3d ___ (1st Cir. Jun. 25, 2012) (court of appeals review of BIA decision is restricted to the ground of the agency's holding); following El Moraghy v. Ashcroft, 331 F.3d 195, 203 (1st Cir. 2003).

Aponte v. Holder, 683 F.3d 6 (1st Cir. Jun. 21, 2012) (granting petition for review on ground BIA failed adequately to address certain issues raised by petitioner).

State v. Sinclair, 2012 Vt. 47 (2012) (the writ of coram nobis is available to pursue 6th Amendment claims for defendants who cannot file under the state PCR statute; the opinion reviews the state of coram nobis law in other jurisdictions, and declines to follow those that have limited or eliminated the availability of the writ (most notably California in an oft-cited decision, People v. Kim)).

People v. Picca, 97 A.D.3d 170, 947 N.Y.2d 120, (N.Y.A.D. 2 Dept. Jun. 6, 2012) (counsel rendered ineffective assistance of counsel when he failed to advise the defendant that he would be subject to removal from the United States pursuant to federal immigration statutes as a consequence of his plea of guilty, and sufficiently alleged that a decision to reject the Peoples plea offer would have been rational, and, thus, that the trial court erred in failing to conduct a hearing on the defendants motion).

People v. Picca, 97 A.D.3d 170, 947 N.Y.2d 120, (N.Y.A.D. 2 Dept. Jun. 6, 2012) (no prejudice existed in Padilla claim where individual circumstances showed that the defendant had previously been convicted of a removable offense, the evidence against him was strong with respect to the instant offense, and the plea bargain he received was favorable).

People v. Picca, 97 A.D.3d 170, 947 N.Y.2d 120, (N.Y.A.D. 2 Dept. Jun. 6, 2012) (the defendant is entitled to application of Padilla because his direct appeal was pending at the time the decision in that case was rendered); see Griffith v. Kentucky, 479 U.S. 314, 328 (1987); People v. Hardy, 4 NY3d 192, 197 (2005).

Vera v. Atty General, 672 F.3d 187 (3d Cir. Mar. 1, 2012) (court may presume visa waiver entrant executed the statutorily required waiver of her right to challenge removal; even if waiver was not signed or invalid, prejudice must also be shown), vacated by Vera v. Att'y Gen, __ F.3d __, 2012 WL 2135508 (3d Cir. Jun. 13, 2012) (DHS discovered petitioner was not a visa waiver program entrant).

Esperanza Alvarado de Rodriguez v. Holder, 585 F.3d 227 (5th Cir. Oct. 9, 2009) (whether the BIA applied an improper standard of review is a question of law, which the court of appeal has jurisdiction to consider: here, the BIA improperly reviewed the IJ's factual findings de novo, when the BIA, while indicating that it did not find any clear error in the immigration judge's factual findings or in its credibility determinations, nonetheless all but ignored significant testimony and documentary evidence that the alien presented as proof of her good faith in entering into marriage).

Ruiz-Lopez v. Holder, 682 F.3d 513, *520 (6th Cir. Jun.