Chaidez v. United States, 133 S.Ct. 1103 (Feb. 20, 2013) (court failed to reach argument that new rules may be reached in post-conviction proceedings raising ineffective assistance of counsel claims because such claims cannot be brought on direct appeal because Chaidez did not raise this argument in the courts below).

Chaidez v. United States, 133 S.Ct. 1103 (Feb. 20, 2013) (A petition for a writ of coram nobis provides a way to collaterally attack a criminal conviction for a person, like Chaidez, who is no longer in custody and therefore cannot seek habeas relief under 28 U.S.C. 2255 or 2241. See United States v. Morgan, 346 U.S. 502, 507, 510"511, 74 S.Ct. 247, 98 L.Ed. 248 (1954).

Chaidez v. United States, 133 S.Ct. 1103 (Feb. 20, 2013) Chaidez and the Government agree that nothing in this case turns on the difference between a coram nobis petition and a habeas petition, and we assume without deciding that they are correct.).

Matter of Garcia-Mendoza, unpublished (BIA Feb. 15, 2013) (A200 582 682) (actual confinement of 180 days or more constitutes a statutory bar to showing good moral character, even after state court nunc pro tunc sentence reduction of the sentence imposed to 166 days).

Patel v. Holder, 707 F.3d 77 (1st Cir. Feb. 1, 2013) (Connecticut conviction of fourth degree larceny under Conn. Gen.Stat. 53a"125, is not categorically a crime of moral turpitude because the offense may be committed without intent to permanently deprive).

Patel v. Holder, 707 F.3d 77, ___ (1st Cir. Feb. 1, 2013) (It is common ground among the parties that theft offenses can meet this definition, and that not all theft offenses do so. As noted above, the BIA generally distinguishes between turpitudinous thefts and their less depraved counterparts by asking whether the defendant intended to permanently deprive the owner of the purloined property.); citing In re Grazley, 14 I. & N. Dec. 330, 333 (BIA 1973).

Patel v. Holder, 707 F.3d 77, ___ n.1 (1st Cir. Feb. 1, 2013) (court declined to consider government argument not the basis of the BIA decision: In this case, however, the BIA treated the permanent-or-temporary-intent question as dispositive, and our review is limited to the reasoning articulated below. Mihaylov v. Ashcroft, 379 F.3d 15, 21 (1st Cir.2004); see Wala v. Mukasey, 511 F.3d 102, 106 (2d Cir.2007) (bypassing this issue where the BIA treated the [permanent intent] inquiry as determinative).).

Pascual v. Holder, 707 F.3d 403,(2d Cir. Feb. 19, 2013) (New York conviction of third-degree criminal sale of a controlled substance, under N.Y. Penal Law 220.39(1), constitutes an aggravated felony, rejecting argument that this statute is not categorically an aggravated felony because statutes that punish offers to sell, see NYPL 220.00(1), are not drug trafficking crimes under the CSA. Davila v. Holder, 381 Fed.Appx. 413, 416 (5th Cir.2010). This Court, however, has held that distribution, within the meaning of 21 U.S.C.

Yeremin v. Holder, 707 F.3d 616 (6th Cir. Feb. 14, 2013) (federal conviction of 18 U.S.C. 1028(f), for conspiracy to traffic in identification documents in violation of 1028(a)(3), which prohibits knowingly possessing with intent to use unlawfully or transfer unlawfully five or more identification documents or false identification documents, constituted a crime of moral turpitude because the conduct prohibited by the statute inherently involves deceit).

Moral-Salazar v. Holder, 708 F.3d 957 (7th Cir. Feb. 28, 2013) (the jurisdictional bar of INA 242(a)(2)(C), 8 U.S.C. 1252(a)(2)(C) does not allow review of the denial of a discretionary motion for continuance).