Missouri v. Frye, 132 S.Ct. 1399 (Mar. 21, 2012) (defendant must show a reasonable probability that the defendant would have accepted, and the prosecution and court would have entered, a more favorable plea bargain absent counsels error).

Missouri v. Frye, 132 S.Ct. 1399 (Mar. 21. 2012) (defense counsel has the duty to communicate to the defendant formal offers from the prosecution to accept a plea on terms and conditions that may be favorable to the accused, and counsel was deficient in failing to communicate to defendant prosecutor's written plea offer before it expired).

Lafler v. Cooper, 132 S.Ct. 1376 (Mar.

Martinez v. Ryan, 132 S.Ct. 1309 (Mar. 20, 2012) (where state law requires a petitioner to raise a claim of ineffective assistance of trial counsel in an initial-review collateral proceeding, state procedural default will not bar a federal habeas court from hearing those claims if, in the initial-review collateral proceeding, there was no counsel or counsel in that proceeding was ineffective).

Martinez v. Ryan, 132 S.Ct. 1309 (Mar.

Matter of Lanferman, 25 I. & N. Dec. 721 (BIA Mar. 9, 2012) (a criminal statute is divisible, regardless of its structure, if, based on the elements of the offense, some but not all violations of the statute give rise to grounds for removal or ineligibility for relief: [W]e have traditionally applied divisibility analysis to all manner of statutes, regardless of their structure. .

Matter of Svetislav Ilic, 25 I.& N. Dec. 717 (BIA 2012) (to independently qualify for adjustment of status under INA 245(i), 8 U.S.C. 1255(i), as a derivative grandfathered alien, the principal beneficiary of the qualifying visa petition must satisfy the requirements for grandfathering, including the physical presence requirement of INA 245(i)(1)(C) of the Act, if applicable).

Matter of Castro Rodriguez, 25 I&N Dec. 698 (BIA 2012) (noncitizen bears burden to establish state conviction of intent to distribute involved a "small amount of marihuana for no remuneration within the meaning of 21 U.S.C. 841(b)(4), which the noncitizen may establish by presenting evidence outside of the record of conviction), Matter of Aruna, 24 I&N Dec. 452 (BIA 2008), clarified.

Matter of Espinosa-Guillot, 25 I&N Dec. 653 (BIA 2011) (an individual whose status was adjusted from parolee to lawful permanent resident pursuant to the Cuban Refugee Adjustment Act of 1966 was admitted for purposes of removal under INA 237(a)); see Lanier v. U.S. Attorney General, 631 F.3d 363, 365-66 (11th Cir. 2011) (individual whose status was adjusted to permanent residence was not barred from seeking a waiver of inadmissibility under INA 212(h)).

Matos-Santana v. Holder, 660 F.3d 91 (1st Cir. Nov. 2, 2011) (affirming BIA denial of motion to reopen removal proceeding as untimely; respondent must first attack the legal validity of a predicate conviction in the court in which the conviction occurred, and may not raise a claim that a conviction is legally invalid before the immigration courts without first doing so).