United States v. Maturin, 499 F.3d 1243 (11th Cir. Sept. 11, 2007) (federal conviction and sentence based on guilty plea to illegally reentering the U.S. after having previously been deported is affirmed over claim that defendant is not subject to a 17-month sentence enhancement as the term of imprisonment for his offense ended more than 15 years before his reentry, as that aggravated felony requirement applies only to foreign convictions).

Kawashima v. Gonzales, ___ F.3d ___, 2007 WL 2702330 (9th Cir. Sept. 18, 2007) (federal conviction for subscribing to a false statement on a tax return, in violation of 26 U.S.C. 7206(1), qualifies as an "aggravated felony" under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), despite argument that (M)(i) is inapplicable in this case, reasoning that (M)(ii)'s specific reference to 7201 indicates Congress's intent to exclude all federal tax offenses from the definition of aggravated felonies under the more general subsection (M)(i)).

Kawashima v. Gonzales, ___ F.3d ___, ___, n.3, 2007 WL 2702330 (9th Cir. Sept. 18, 2007) (federal convictions for subscribing to a false statement on a tax return, in violation of 26 U.S.C. 7206(1), and aiding and abetting in the preparation of a false tax return, in violation of 26 U.S.C. 7206(2), cannot qualify as an "aggravated felony" under INA 101(a)(43)(M)(ii), 8 U.S.C. 1101(a)(43)(M)(ii), because that provision is limited to tax offenses in violation of 7201); following United States v. Roselli, 366 F.3d 58, 62 n.5 (1st Cir. 2004).

De Vega v. Gonzales, __ F.3d __, 2007 WL 2696489 (1st Cir. Sept. 17, 2007) (Fleuti doctrine did not survive amendments to INA 101(a)(13) made as part of IIRAIRA), agreeing with Malagon de Fuentes v. Gonzales, 462 F.3d 498, 501 (5th Cir. 2006); Tapia v. Ashcroft, 351 F.3d 795, 799 (7th Cir.2003); Tineo v. Ashcroft, 350 F.3d 382, 394 (3d Cir.2003)). Note: both the conviction and travel occurred after April 1, 1997.

De Vega v. Gonzales, __ F.3d __, 2007 WL 2696489 (1st Cir. Sept. 17, 2007) (Massachusetts continuance of a criminal case based on an admission of facts sufficient for a finding of guilt and conditioned on payment of restitution constitutes a "conviction" under INA 101(a)(48)(A), 8 U.S.C. 1101(a)(48)(A) for immigration purposes, even though no actual finding of guilt had been made in this case).

Fernandez v. Keisler, ___ F.3d ___, 2007 WL 3036814 (2d Cir. Sept. 26, 2007) (noncitizen did not qualify as a "national" of the United States as one who owes "permanent allegiance" to the United States and thus qualifies as a U.S. national under INA 101(a)(22)(B), 8 U.S.C. 1101(a)(22)(B) (West 2005)).

Biskupski v. Attorney Gen. of the US, __ F.3d __, 2007 WL 2774528 (3d Cir. Sept. 25, 2007) (federal misdemeanor conviction of violating 8 U.S.C. 1324(a)(2)(A), aiding and abetting alien smuggling, is an "aggravated felony" even though only punishable as a misdemeanor under federal law).

Biskupski v. Attorney Gen. of the US, __ F.3d __, 2007 WL 2774528 (3d Cir. Sept. 25, 2007) (federal misdemeanor conviction of violating 8 U.S.C. 1324(a)(2)(A), aiding and abetting alien smuggling, is an "aggravated felony" even though only punishable as a misdemeanor under federal law).

Biskupski v. Attorney Gen. of the US, __ F.3d __, 2007 WL 2774528 (3d Cir. Sept. 25, 2007) (aggravated felony definition not impermissibly retroactive; the term "actions taken" in section 321(c) of IIRAIRA refers to orders and decisions of an IJ or the BIA to apply "aggravated felony" definition, not to actions taken by the noncitizen).

United States v. Sinerius, __ F.3d __, 2007 WL 2728760 (9th Cir. Sept. 20, 2007) ("The phrase relating to, as defined by the Supreme Court, means to stand in some relation to; to have bearing or concern; to pertain; refer; to bring into association with or connection with. Morales v. Trans World Airlines, 504 U.S. 374, 383, 112 S.Ct. 2031, 119 L.Ed.2d 157 (1992) (quoting Black's Law Dictionary 1128 (5th ed.1979)) (construing relating to in a different statutory context). We have construed relating to language broadly in the past, see Luu-Le v.