Descamps v. United States, 570 U.S. ___, 133 S.Ct. 2276 (June 20, 2013) (the modified categorical approach does not authorize a fact-based inquiry; court may use the modified approach only to determine which alternative element in a divisible statute formed the basis of the conviction.).

United States v. Gomez, __ F.Supp.2d __, 2013 WL 2147021 (S.D. Fla. May 15, 2013) (revoking naturalization where noncitizen failed to disclose conviction for drug trafficking on naturalization application).

Alleyne v. United States, __ S.Ct. __ (2013) (any fact that increases the mandatory minimum is an "element" that must be submitted to the jury, rather than the judge).

In Judulang, the Court rejected a rule that categorically excluded a group of deportable
LPRs on grounds that bore no relationship to the aliens fitness to remain in the country. Judulang v. Holder, 565 U.S. """", """", 132 S.Ct. 476, 485, 181 L.Ed.2d 449 (2011). Op. at 12. Categorical exclusion of trial conviction cases also bears no relationship to fitness to remain. Indeed, the agency has never claimed that it bore such a relationship. Instead, trial conviction cases have been excluded from relief on the ground that St. Cyr does not require that they be included. See, e.g., Canto v.

Matter of ESI, 26 I&N Dec. 136 (BIA 2013) (where respondents mental incompetency appears manifest, the DHS should serve the notice to appear on: (1) a person with whom the respondent resides and who will be in a position of demonstrated authority; (2) a relative, guardian, or person similarly close to the respondent; and (3) the respondent).

Matter of Rivas, 26 I&N Dec. 130 (BIA 2013) (waiver of inadmissibility under INA 212(h) is not available on a stand-alone basis; waiver must be pursuant to an application for adjustment of status; waiver may not be granted nunc pro tunc to avoid requirement that noncitizen must establish eligibility for adjustment).

Chhabra v. United States, __ F.3d __ (2d Cir. Jun. 20, 2013) (federal writ of error coram nobis to vacate conviction on the basis of ineffective assistance of counsel was untimely, and defendant did not establish prejudice, where defendant consulted with an immigration attorney on advice of defense counsel after the plea but before sentencing, and did not thereafter move to withdraw the plea).

Chhabra v. United States, __ F.3d __ (2d Cir. Jun. 20, 2013) (federal writ of error coram nobis to vacate conviction on the basis of ineffective assistance of counsel was untimely, and defendant did not establish prejudice, where defendant consulted with an immigration attorney on advice of defense counsel after the plea but before sentencing, and did not thereafter move to withdraw the plea).

Flores v. USCIS, __ F.3d __ (6th Cir. Jun. 4, 2013) (plain language of INA 244(f)(4) allows noncitizen who entered without inspection, then obtained TPS, to become an LPR despite illegal entry, and provides an exception to the inspected and admitted or paroled language of INA 245(a)).

United States v. Zamudio, 718 F.3d 989 (7th Cir. Jun. 4, 2013) (without imposing supervised release, criminal judge may not impose immigration-related conditions such as requiring defendant to report to ICE or to remain outside the United States if removed).