Attorney General Kamala D. Harris issued an information bulletin to California law enforcement agencies on their responsibilities and potential liability for complying with Immigration and Customs Enforcement (ICE) federal detainer requests. She informed then of the new requirements they face since enactment of the California Transparency and Responsibility Using State Tool Act (TRUST Act) and new federal case law that creates a legal liability risk for local law enforcement agencies that voluntarily comply with federal detainer requests.

In People v. Palmer, the California Supreme Court held that as part of a defendants change of plea, there is no invariable requirement that the defense stipulate to any specific document in order to establish a factual basis for the plea. It seems clear, under People v.

Mejia v. Holder, ___ F.3d ___, 2014 WL 2872220 (1st Cir. Jun.

Mayorga v. Attorney General U.S., ___ F.3d ___, 2014 WL 2898528 (3d Cir. Jun. 27, 2014) (federal conviction of unlicensed business of firearms dealing, in violation of 18 U.S.C. 922(a)(1)(A) and (a)(2), did not categorically constitute a crime of moral turpitude, since the offense is a regulatory/licensing offense); see Matter of Abreu"Semino, 12 I. & N. Dec. 775, 776 (BIA 1968) (the violation of a regulatory, or licensing, or revenue provision of a statute is not a crime involving moral turpitude).

United States v. Spear, ___ F.3d ___, 2014 WL 2523649 (9th Cir. Jun. 5, 2014) (knowing and voluntary waiver of the right to appeal sentence did not waive right to appeal of conviction after plea of guilty).

Butler v. Long, ___ F.3d ___, 2014 WL 1717009 (9th Cir. May 2, 2014) (reversing dismissal of habeas corpus petition, since the trial court dismissed a previous petition containing both exhausted and unexhausted claims, without providing petitioner an opportunity to amend, he was entitled to equitable tolling from the date of the first dismissal until the filing of the current petition; since equitable tolling renders at least one of his claims timely).

United States v. Aguilera-Rios, ___ F.3d ___, 2014 WL 2723766 (9th Cir. Jun. 17, 2014) (California Penal Code 12021(c)(1), current Penal Code 29800, is not a categorical aggravated felony firearms offense, since the statute lacks an antique firearms exception); explicitly partially overruling Gil v. Holder, 651 F.3d 1000, 1005"06 (9th Cir. 2011), and implicitly partially overruling Matter of Mendez-Orellana, 25 I&N Dec. 254 (BIA 2010).

United States v. Jackson, ___ F.3d ___, 2014 WL 2747193 (9th Cir. Jun. 18, 2014) (reversing federal misdemeanor conviction for unlawfully manufacturing a U.S. identification card, in violation of 18 U.S.C.

Castillo v. U.S. Atty Gen., ___ F.3d ___, ___, 2014 WL 2915918 (11th Cir. Jun. 27, 2014) (aggravated felony conviction continues to trigger deportation, under INA 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii), even though the Georgia State Board of Pardons and Paroles had earlier pardoned noncitizen for the conviction that rendered him removable: Under the plain meaning of 1227(a)(2)(A)(vi), a pardon is only full when it restores the totality of rights abrogated by the underlying conviction.

People v. Leiva, 56 Cal. 4th 498, 502 (2013) (summary revocation of probation allowed trial court to retain authority to adjudicate only probation violations during the probation term: summary revocation operated in conjunction with the tolling provision of Pen. Code, 1203.2, subd. (a), to preserve the trial court's authority to adjudicate a claim of a probation violation during the original probationary period and to extend or otherwise modify probation under Pen. Code, 1203.3, subd. (a)); disapproving People v. DePaul, 137 Cal.App.3d 409, 187 Cal.Rptr. 82.