United States v. Thum, 749 F.3d 1143 (9th Cir. 2014) (escorting a noncitizen from a fast food restaurant to a nearby vehicle does not constitute encouraging or inducing an alien to reside in the United States, and is not aiding and abetting commission of a crime)

United States v. Dominguez-Maroyoqui, 748 F.3d 918 (9th Cir. Apr. 7, 2014) (federal conviction for assaulting a federal officer, in violation of 18 U.S.C. 111(a), is not categorically a crime of violence for illegal re-entry sentencing purposes, since the offense does not require, as an element, proof that defendant used, attempted to use, or threatened to use physical force).

Forbess v. Franke, 749 F.3d 837 (9th Cir. Apr. 18, 2014) (untimely habeas petition under 28 U.S.C. 2254 allowed where petitioner suffered from delusions so severe that he was unable to understand the need to timely file his petition).

Miranda-Olivares v. Clackamas County, ___ F. Supp. 2d ___ (D. Or. Apr. 11, 2014) (8 CFR 287.7 does not require law enforcement to detain suspected noncitiens upon receipt of a Form I"247; county officials violated fourth amendment rights to due process by holding noncitizen in custody of jail solely on the basis of an immigration detainer, which constituted a new seizure; ICE detainer is not sufficient basis for jail to reasonably conclude it had probable cause to detain past the release date; county may be held liable for any period of unlawful detention), citing Galarza v.

People v. Zuniga, 225 Cal.App.4th 1178, 170 Cal.Rptr.3d 811 (Cal.App. 4 Dist., Apr. 28, 2014) (California conviction of violating Penal Code 288a(b)(1), oral copulation with a minor, is not a crime of moral turpitude since there is no scienter requirement or age gap required and minor could be any person under 18).

People v. Arriaga, 58 Cal.4th 950, 169 Cal.Rptr.3d 678 (Apr. 7, 2014) (certificate of probable cause is not required to appeal order denying a motion to vacate a conviction under Penal Code section 1016.5; when proof immigration advisement is not adequately shown in the record, the prosecution must prove by a preponderance of the evidence that the advisements were given).

Kovacs v. U.S., 744 F.3d 44, 52 (2d Cir. Mar. 3, 2014) (We conclude that a defense lawyer's incorrect advice about the immigration consequences of a plea is prejudicial if it is shown that, but for counsel's unprofessional errors, there was a reasonable probability that the petitioner could have negotiated a plea that did not impact immigration status or that he would have litigated an available defense. [Footnote omitted.] See United States v. Kwan, 407 F.3d 1005, 1017"18 (9th Cir.2005) (Kwan could have gone to trial or renegotiated his plea agreement to avoid deportation.).

Kovacs v. U.S., 744 F.3d 44, 52 (2d Cir. Mar. 3, 2014) (petitioner showed reasonable probability he would have litigated an available statute of limitations defense if he had been unable to negotiate an immigration-neutral disposition, which was a sufficient showing of prejudice from counsels ineffective assistance in affirmatively misadvising him of the adverse immigration consequences of his plea).

The court stated:

Alternatively, Kovacs demonstrates prejudice under the standards set forth in Hill.

Kovacs v. U.S., 744 F.3d 44, 54 (2d Cir. Mar. 3, 2014) (No statute of limitations governs the filing of a coram nobis petition. See Foont, 93 F.3d at 79. At the same time, the petitioner must demonstrate sound reasons for any delay in seeking relief. Id. The critical inquiry ... is whether the petitioner is able to show justifiable reasons for the delay. Id. at 80.).

The court stated:

Kovacs has supplied sufficient reasons to justify the delay.

Parra-Rojas v. Attorney General U.S., ___ F.3d ___, ___, 2014 WL 1230001 (3d Cir. Mar. 26, 2014) (federal conviction of Bringing In or Harboring Aliens for Financial Gain, in violation of INA 274(a)(2)(B)(ii), 8 U.S.C. 1324(a)(2)(B)(ii), did not trigger inadmissibility under INA 212(a)(6)(E)(i), 8 U.S.C. 1182(a)(6)(E)(i) (the smuggling bar), which renders an alien inadmissible if he has knowingly ...