Masih v. Aviles, __ F.Supp.2d ___ (S.D.N.Y. May 20, 2014) (noncitizen held not subject to INA 236(c), because noncitizen had never been released from criminal custody in relation to a removable offense; mandatory detention is not triggered upon release from pre-trial custody, and termination of probation also does not constitute release from criminal custody for mandatory detention purposes).

Syblis v. Attorney General of U.S., ___ F.3d ___, ___, 2014 WL 4056557 (3d Cir. Aug. 18, 2014) (Virginia conviction of possession of drug paraphernalia, in violation of Va.Code Ann. 54.1"3466, constituted a conviction relating to a controlled substance, for immigration purposes: we are satisfied that Va.Code Ann. 54 .1"3466 is sufficiently connected to controlled substances so as to be related to controlled substances for purposes of 1182(a)(2)(A)(i)(II). See Luu"Le, 224 F.3d at 915 (Although the definition of drug ... does not map perfectly the definition of controlled substance ...

Avila-Ramirez v. Holder, ___ F.3d ___, 2014 WL 4099729 (7th Cir. Aug. 21, 2014) (reversing BIA denial of discretionary relief from removal, where BIA failed to follow its own precedent by giving undue weight to uncorroborated arrest reports where respondent denied any wrongdoing).

United States v. Mageno, __ F.3d __ (9th Cir. Aug. 11, 2014) (prosecutors misstatements of facts during closing arguments encouraged jury to convict based on evidence not presented at trial).

Rendon v. Holder, ___ F.3d ___, ___, 2014 WL 4115930 (9th Cir. Aug.

United States v. Cisneros, ___ F.3d ___ 2014 WL 4067214 (9th Cir. Aug. 19, 2014) (Oregon conviction for fleeing or attempting to elude police officers under ORS 811.540(1), is divisible for purposes of the ACCA, since the offense is a misdemeanor if the defendant fled on foot, but a felony if he fled by car).

Nguyen v. Holder, ___ F.3d ___, ___ n.4, 2014 WL 3953758 (9th Cir. Aug. 14, 2014) (whether federal conviction of misuse of a passport without intent to facilitate an act of international terrorism, under 18 U.S.C. 1544, 2331, categorically constitutes a crime of moral turpitude, is an open question).

Ramirez-Coria v. Holder, __ F.3d __ (10th Cir. Aug. 1, 2014) (IJ did not abuse discretion in denying relief for noncitizens failure to obtain required biometrics).

People v. Panizzon, 13 Cal.4th 68, 913 P.2d 1061, 1073-1074 (April 18, 1996) ([a]n appellate court may correct a sentence that is not authorized by law whenever the error comes to the attention of the court); quoting In re Harris (1993) 5 Cal.4th 813, 842, 21 Cal.Rptr.2d 373, 855 P.2d 391).

The court went on to qualify this general statement:

[The] defendant argues that California decisional law has long recognized the necessity of affording judicial review where, as here, a sentence is challenged as invalid or in excess of the court's jurisdiction.

Counsel can argue that police reports are inadmissible in removal proceedings for the following reasons:

1. Police reports are unreliable. (United States v. Johnson, ___ F.3d ___ (8th Cir. 2013). To overcome a hearsay objection, the government would need to call the officer who wrote it as a witness, subject to cross-examination. INA 240b4B. Cinapian v. Holder, 567 F.3d 1067, 1074 (9th Cir.