Matter of Chairez, 26 I&N Dec. 349 (BIA 2014) (Utah conviction for violation of 76-10-508.1(1)(b) and (c), discharge of a firearm in the direction of a building, person, or vehicle, is categorically an aggravated felony crime of violence).

United States v. Valdovinos, ___ F.3d ___, ___, 2014 WL 3686104 (4th Cir. Jul. 25, 2014) (Davis, Senior Circuit Judge, dissenting) (Our disagreement as to the outcome in this case stems, I think, less over the content and application of relevant precedent and more from a fundamental disagreement regarding our role as arbiters of a flailing federal sentencing regime.

Alvarado v. Holder, ___ F.3d ___, 2014 WL 3608713 (9th Cir. Jul. 23, 2014) (Arizona conviction for attempted possession of a dangerous drug, in violation of Arizona Revised Statute 13-3407(A)(1), constituted a violation of state law relating to a controlled substance, for purposes of deportation, under the modified categorical analysis, where attachment to the plea agreement set the factual basis, which identified the controlled substance as methamphetamines).

NOTE: The court found that the argument that Arizona attempt is broader than federal attempt was waived for failure to exhaust.

United States v. Jimenez-Arzate, 553 Fed.Appx. 700 (9th Cir. Jan. 24, 2014), panel rehearing granted, Jul. ___, 2014, ___ F.3d ___ (9th Cir. 2014) (California conviction for assault with a deadly weapon, in violation of Penal Code 245(a), is an aggravated felony crime of violence), rehearing granted since this conviction may no longer be a categorical match for the aggravated felony crime of violence definition, in light of the recent Ninth Circuit en banc decision in Ceron v. Holder, 747 F.3d 773 (9th Cir. Mar. 31, 2014).
Thanks to Kara Hartzler.

Torres v. Holder, ___ F.3d ___, ___, 2014 WL 4085865 (2d Cir. Aug. 20, 2014) (New York conviction of third-degree attempted arson, in violation of New York Penal Law 110, 150.10, constitutes an aggravated felony arson offense, despite lacking a federal jurisdictional element: Because we conclude that the statute is ambiguous, we owe deference to the BIA's interpretation unless it is unreasonable. See Chevron, 467 U.S. at 842"43; Rotimi v. Holder, 577 F.3d 133, 139 (2d Cir.2009).); accord, Spacek v. Holder, 688 F.3d 536 (8th Cir.2012) (interpreting 8 U.S.C.

Syblis v. Attorney General of U.S., ___ F.3d ___, ___, 2014 WL 4056557 (3d Cir. Aug. 18, 2014) (BIA acknowledged that Va.Code Ann. 54.1"3466 punished drug paraphernalia offenses related to substances not included within the CSA, such as those recognized by the official United States Pharmacopoeia National Formulary).

Counsel can argue that police reports are inadmissible in removal proceedings for the following reasons:

1. Police reports are unreliable. (United States v. Johnson, ___ F.3d ___ (8th Cir. 2013). To overcome a hearsay objection, the government would need to call the officer who wrote it as a witness, subject to cross-examination. INA 240b4B. Cinapian v. Holder, 567 F.3d 1067, 1074 (9th Cir.

Several states have reduced the maximum sentence for misdemeanor offenses to 364 days. They include at least California, Nevada, New Mexico, and Washington. E.g., California Penal Code 18.5 (effective Jan. 1, 2014).

Matter of Chairez, 26 I&N Dec. 349 (BIA 2014) (Utah conviction for violation of 76-10-508.1(1)(a), discharge of a firearm, is not categorically an aggravated felony crime of violence, since the offense may be committed recklessly).

Arapahoe County, Colorado, agreed to pay $30,000 to Claudia Valdez who was illegally held by the county jail for three days on an ICE detainer in 2012. See ACLU website, http://aclu-co.org/colorado-sheriff-pay-30k-woman-held-immigration-detai....
Thanks to Hans Meyer, Esq