Gonzalez v. Holder, __ F.3d __ (5th Cir. Oct. 21, 2014) (noncitizen not entitled to derivative citizenship where noncitizen did not apply for lawful permanent residence until he was 23).

United States v Warnell Reid, ___ F.3d ___, 2014 WL 5314563 (8th Cir. Oct 20, 2014) (Missouri conviction for attempted burglary is not a violent felony under the Armed Career Criminal Act, 18 U.S.C.

Avendano v. Holder, 770 F.3d 731 (8th Cir. Oct. 27, 2014) (Minnesota conviction of making terroristic threats, in violation of Minn.Stat. 609.713(1) [threatening to commit a crime of violence in reckless disregard of the risk of causing terror in his girlfriend], is categorically a crime of moral turpitude, where, as here, Recklessness requires deliberate action in disregard of a known, substantial risk.); citing Matter of Louissaint, 24 I. & N. Dec.

Padilla-Martinez v. Holder, ___ F.3d ___, ___, n.3, 2014 WL 5421219 (9th Cir. Oct.

Padilla-Martinez v. Holder, ___ F.3d ___, 2014 WL 5421219 (9th Cir. Oct. 27, 2014) (failure to fully comply with the terms of the statute and regulation [8 U.S.C. 1229a(c)(3); 8 C.F.R. 1003.41] does not render electronic conviction records inadmissible; holding admissible an uncertified facsimile copy of a transcript of the state court felony change-of-plea proceedings to establish drug-trafficking aggravated felony conviction); citing Sinotes"Cruz v. Gonzales, 468 F.3d 1190, 1195"96 (9th Cir.

Espino-Castillo v. Holder, ___ F.3d ___, 2014 WL 5462309 (9th Cir. Oct. 29, 2014) (Arizona conviction of forgery, in violation of Arizona Revised Statutes 13-2002, is categorically a crime involving moral turpitude because the statute requires fraudulent intent; Beltran-Tirado v. INS, has not been applied to a state statute); discussing Beltran-Tirado v. INS, 213 F.3d 1179 (9th Cir.

People v. Vargas, 110 Cal. Rptr. 2d 210, 247 (2001) (the object of a conspiracy is not an element of a California conspiracy offense: [T]he specific crimes that constitute the object of the conspiracy are not elements of the conspiracy. Rather, they are the means by which the purpose of the conspiracy was to be achieved.); id. at 245 (So long as there is unanimity that crime was the object of the agreement, conspiracy is established regardless of whether some jurors believe that crime to be murder and others believe that crime to be something else.).

Note: As long as Rendon v.

De Martinez v. Holder, ___ F.3d ___, 2014 WL 5394445 (9th Cir. Oct. 24, 2014) (per curiam) (Arizona conviction of criminal impersonation, in violation of Arizona Revised Statutes 13"2006(A)(1), is categorically a crime involving moral turpitude, because the statute explicitly requires proof of fraudulent intent).

United States v. Hernandez, 769 F.3d 1059 (9th Cir. Oct. 20, 2014) (per curiam) (California conviction for being a felon in possession of a firearm under California Penal Code 12021(a)(1), did not categorically qualify as a listed firearms aggravated felony, under INA 101(a)(43)(E), 8 U.S.C.