Ram v. Mukasey, 529 F.3d 1238 (9th Cir. Jun. 26, 2008) (finding waiver of counsel was not knowing or voluntary, given noncitizens obvious difficulties during proceedings despite strong arguments available to him).

Rashid v. Mukasey, 531 F.3d 438 (6th Cir. Jun. 26, 2008) (Michigan conviction of possession of a controlled substance, where the defendant has a prior conviction for the same offense, is not an aggravated felon under INA 101(a)(43)(B) for immigration purposes; "The first and only hypothetical that should be considered under the hypothetical federal felony approach is whether the crime that an individual was actually convicted of would be a felony under federal law.

Flores-Juarez v. Mukasey, 530 F.3d 1020 (9th Cir. Jun. 26, 2008) (the bar to non-LPR cancellation of removal for noncitizens who fall within certain criminal grounds of removal, under INA 240A(b)(C), applies regardless of the date of the conviction; the 10-year Good Moral Character requirement under INA 240A(b)(B) does not also impose a 10 year limit on the period in which the criminal convictions must have occurred).

Matter of Gonzalez-Zoquiapan, 24 I. & N. Dec. 549 (BIA Jun. 25, 2008) (California conviction for violation of California Penal Code 647(b), disorderly conduct involving solicitation of a prostitute does not fall within INA 212(a)(2)(D)(ii) ground of inadmissibility [procuring a prostitute]; that ground only applies to persons who engage in the business of obtaining prostitutes for use by others, not to isolated incidents of people hiring a prostitute; because soliciting a prostitute does not trigger INA 212(a)(2)(D), it does not bar good moral character on that basis).

Arar v. Ashcroft, 532 F.3d 157 (2d Cir. Jun. 30, 2008) (no claim exists under the Torture Victim Protection Act or Fifth Amendment for dual Syrian/Canadian citizen who alleges mistreatment by the United States on the basis he was removed to Syria despite the U.S. having knowledge he would be tortured).

Matter of Gonzalez-Zoquiapan, 24 I. & N. Dec. 549 (BIA Jun. 25, 2008) (California conviction for violation of California Penal Code 647(b), disorderly conduct, is broader than the prostitution ground of inadmissibility; the phrase "engage in prostitution" for purposes of INA 212(a)(2)(D) means to engage in a pattern or practice of sexual intercourse for financial or other material gain; the phrase does not encompass isolated incidents or sexual contact that falls short of intercourse).

Matter of Gonzalez-Zoquiapan, 24 I. & N. Dec. 549 (BIA Jun. 25, 2008) (reaffirming that CMT offense that falls within petty offense exception to inadmissibility does not create bar to good moral character), following Matter of Garcia-Hernandez, 23 I. & N. Dec. 590, 593 (BIA 2003).

United States v. Montgomery, 150 F.3d 983, 1002 (9th Cir. 1998) ("[E]vidence of a mere buyer-seller relationship is insufficient to support a conspiracy conviction [unless there is third party involvement, or it was agreed between them that the drugs would be further distributed]."); United States v. Lennick, 18 F.3d 814, 819 (9th Cir. 1994) ("[P]roof that a defendant sold drugs to other individuals does not prove the existence of a conspiracy.");.accord United States v. Douglas, 818 F.2d 1317, 1321 (7th Cir.

United States v. Montgomery, 150 F.3d 983, 1002 (9th Cir. 1998) ("[E]vidence of a mere buyer-seller relationship is insufficient to support a conspiracy conviction [unless there is third party involvement, or it was agreed between them that the drugs would be further distributed]."); United States v. Lennick, 18 F.3d 814, 819 (9th Cir. 1994) ("[P]roof that a defendant sold drugs to other individuals does not prove the existence of a conspiracy.");.accord United States v. Douglas, 818 F.2d 1317, 1321 (7th Cir.

United States v. Montgomery, 150 F.3d 983, 1002 (9th Cir. 1998) ("[E]vidence of a mere buyer-seller relationship is insufficient to support a conspiracy conviction [unless there is third party involvement, or it was agreed between them that the drugs would be further distributed]."); United States v. Lennick, 18 F.3d 814, 819 (9th Cir. 1994) ("[P]roof that a defendant sold drugs to other individuals does not prove the existence of a conspiracy.");.accord United States v. Douglas, 818 F.2d 1317, 1321 (7th Cir.