In Arsdi v. Holder, 659 F.3d 925 (9th Cir. Oct. 24, 2011), the Ninth Circuit held it lacked jurisdiction to consider petition for review of claim that Immigration Judge used wrong standard to decide whether conviction was for particularly serious crime to bar relief, since the petitioner failed to exhaust the claim by presenting it to the BIA in a way that afforded the BIA notice and a chance to correct its own errors. He made only a general allegation that the IJ erred in denying him relief, and failed to specify which issues form the basis of the appeal. INA 242(d)(1), 8 U.S.C.

Arsdi v. Holder, 659 F.3d 925, 930 (9th Cir. Oct. 24, 2011) (As the government points out, an alien may also move for reconsideration or reopening of the IJs decision. See 8 U.S.C. 1229a(c)(6)-(7). Because these motions are not remedies available to the alien, as of right, an alien need not use them in order to exhaust his claim. 8 U.S.C. 1252(d)(1). However, these multifarious methods of review highlight the import Congress placed on allowing the agency to correct its own mistakes prior to interference by the federal courts.).

Arsdi v. Holder, 659 F.3d 925, 930 (9th Cir. Oct. 24, 2011) (As the government points out, an alien may also move for reconsideration or reopening of the IJs decision. See 8 U.S.C. 1229a(c)(6)-(7). Because these motions are not remedies available to the alien, as of right, an alien need not use them in order to exhaust his claim. 8 U.S.C. 1252(d)(1). However, these multifarious methods of review highlight the import Congress placed on allowing the agency to correct its own mistakes prior to interference by the federal courts.).

James v. Schriro, 659 F.3d 855 (9th Cir. Oct. 12, 2011) (prejudicial failure to investigate social history, mental state, and drug abuse required reversal of the sentence).

James v. Schriro, 659 F.3d 855 (9th Cir. Oct. 12, 2011) (an error of law is an abuse of discretion); Strauss v. Comm'r, 635 F.3d 1135, 1137 (9th Cir.2011) (An error of law is an abuse of discretion.).

United States v. Sykes, 658 F.3d 1140 (9th Cir. Sept. 26, 2011) (affirming denial of motion to reduce sentence pursuant to 18 U.S.C. 3582(c)(2), based on the claim the district court's modification of his sentence to the 120"month mandatory minimum term pursuant to 21 U.S.C. 841(b)(1)(A) constituted the application of a new sentence, in violation of Dillon v. United States, ___ U.S. ___, 130 S.Ct. 2683, 177 L.Ed.2d 271 (2010), because it concluded that the district court's application of the 120"month mandatory minimum term pursuant to 18 U.S.C.

Jiang v. Holder, 658 F.3d 1118 (9th Cir. Sept. 26, 2011) (We weigh four factors to determine whether the BIA has abused its discretion in denying a continuance: 1) the importance of the evidence, 2) the unreasonableness of the immigrant's conduct, 3) the inconvenience to the court, and 4) the number of continuances previously granted.); citing Cui v. Mukasey, 538 F.3d 1289, 1292 (9th Cir.2008); citing Baires v. INS, 856 F.2d 89, 92"93 (9th Cir.1988).

United States v. Ruiz-Apolonio, 657 F.3d 907 (9th Cir. Sept. 14, 2011) (California conviction of forcible rape, under Penal Code 261(a)(2), is categorically a "crime of violence" as defined by the Sentencing Guidelines).

United States v. Ayala-Nicanor, 659 F.3d 744 (9th Cir. Sept. 14, 2011) (California conviction of corporal injury of a spouse, under Penal Code 273.5(a), is a categorical crime of violence for illegal re-entry sentencing purposes).

Trigueros v. Adams, 658 F.3d 983 (9th Cir. Sept. 14, 2011) (state court's request for informal briefing from the people on appellant's state habeas corpus petition constituted a finding of timeliness and a final decision on the merits by that state court such that appellant's federal petition, filed less than a month after the findings, is timely under the AEDPA, since the AEDPA statute of limitations is tolled by the filing of a state post-conviction petition).