In People v. Palmer, the California Supreme Court held that as part of a defendants change of plea, there is no invariable requirement that the defense stipulate to any specific document in order to establish a factual basis for the plea. It seems clear, under People v.

Mejia v. Holder, ___ F.3d ___, 2014 WL 2872220 (1st Cir. Jun.

Mayorga v. Attorney General U.S., ___ F.3d ___, 2014 WL 2898528 (3d Cir. Jun. 27, 2014) (federal conviction of unlicensed business of firearms dealing, in violation of 18 U.S.C. 922(a)(1)(A) and (a)(2), did not categorically constitute a crime of moral turpitude, since the offense is a regulatory/licensing offense); see Matter of Abreu"Semino, 12 I. & N. Dec. 775, 776 (BIA 1968) (the violation of a regulatory, or licensing, or revenue provision of a statute is not a crime involving moral turpitude).

Castillo v. U.S. Atty Gen., ___ F.3d ___, ___, 2014 WL 2915918 (11th Cir. Jun. 27, 2014) (aggravated felony conviction continues to trigger deportation, under INA 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii), even though the Georgia State Board of Pardons and Paroles had earlier pardoned noncitizen for the conviction that rendered him removable: Under the plain meaning of 1227(a)(2)(A)(vi), a pardon is only full when it restores the totality of rights abrogated by the underlying conviction.

Matter of Introcaso, 26 I. & N. Dec. 304 (BIA May 20, 2014) (petitioner bears the burden of proving whether an offense is specified offense against a minor; the categorical approach does not apply to this determination, and DHS can look into the underlying facts of a conviction, even where the elements of the criminal statute would not have supported a finding of ineligibility).

Matter of Jackson, 26 I. & N. Dec. 314 (BIA May 20, 2014) (Adam Walsh Act applies to all convictions suffered by any United States citizen at any time, even those occurring before the AWAs enactment).

Donnee v. Holder, ___ F.3d ___, 2014 WL 1856738 (1st Cir. May 9, 2014) (a grant of Temporary Protected Status by the Department of Homeland Security only served to prevent execution of the removal order; it did not affect the validity of the order).

Go v. Holder, 744 F.3d 604 (9th Cir. Mar. 7, 2014) (the specific time and number limitations on motions to reopen, 8 C.F.R. 1003.2(c), apply to motions to reopen that arise under the Convention Against Torture).

Unlike circuit courts, where only an en banc decision can overrule a three-judge panel, a three-member panel of the Board can overrule any prior precedential decision. See, e.g., Matter of Alyazji, 25 I&N Dec. 397 (BIA 2011). Presumably, this is because a decision can only be designated as precedential following a vote in which it receives the support of a majority of permanent Board members. 8 CFR 1003.1(g). Thus, even when a decision only contains the names of three members, it has the support of a majority of the Board's permanent members. Thanks to Ben Winograd.

Matter of Abdelghany, 26 I&N Dec. 254, 269 (BIA 2014)(the BIA drew no distinction, for the purpose of retroactivity of eligibility for relief under former INA 212(c), between convictions at trial or guilty pleas, and found unpersuasive precedential decisions demanding a showing of detrimental reliance on the availability of relief: a lawful permanent resident convicted after trial need not demonstrate that he acted or could have acted in reliance on the availability of 212(c) relief when structuring his conduct.