United States v. Hernandez-Arias, 745 F.3d 1275 (9th Cir. Mar. 21, 2014) (termination of defendant's temporary status operated to revoke any "admission" resulting from the prior adjustment of status, rendering the defendant unadmitted and removable, so removal order was not fundamentally unfair).

United States v. Cabrera-Gutierrez, ___ F.3d ___, 2014 WL 998173 (9th Cir. Mar. 17, 2014), withdrawing and superseding previous opinion on grant of panel rehearing (Oregon conviction of sexual abuse in the second degree, in violation of Or.Rev.Stat. 163.425, does not trigger a sentence for a federal conviction for failing to register under the Sex Offender Registration and Notification Act, 18 U.S.C. 2250, as a Tier III sex offender, because the Oregon statute is not divisible: The statute states a single, indivisible set of elements, and the modified categorical approach does not apply.

Turijan v. Holder, 744 F.3d 617, 622 n.3 (9th Cir. Mar. 10, 2014) (The BIA's unreasoned reliance on a state court decision ... is not of great weight because it relates to the very different issue of whether a crime is morally turpitudinous for purposes of California evidence law, lacks power to persuade and thus is not entitled to deference.); quoting Castrijon-Garcia v. Holder, 704 F.3d 1205, 1211 and n.6 (9th Cir. Jan. 9, 2013).

Perez-Palafox v. Holder, 744 F.3d 1138 (9th Cir. Mar. 11, 2014) (California conviction for transportation of methamphetamine, in violation of California Health and Safety Code 11379(a), constituted a particularly serious crime for purposes of barring withholding of removal).

Montoya v. Holder, 744 F.3d 614 (9th Cir. Mar. 7, 2014) (applying the IIRAIRA reinstatement statute, 8 U.S.C. 1231(a)(5) (the alien is not eligible and may not apply for any relief under this chapter), to petitioner was not impermissibly retroactive even though her brother had filed a Form I-130 petition for alien relative on her behalf before the Act's effective date, because she took no pre-enactment action sufficient to create a vested right to apply for adjustment of status).

Matter of Islam, 25 I&N Dec. 637, 643 (BIA 2011) (very restrictive interpretation of single scheme exception for multiple moral turpitude conviction ground of deportability, calling into question the authority of older cases with a more generous interpretation: the BIA cited to Chevron and Brand X and concluded: "We respectfully conclude that our analysis there is controlling and should now be uniformly applied in all circuits throughout the country.").

Note: There is a good argument, however, to the contrary. E.g., Gonzalez-Sandoval v. U.S. INS, 910 F.2d 614 (9th Cir.

Matter of Chavez-Alvarez, 26 I. & N. Dec. 274 (BIA Mar. 14, 2014) (adjustment of status constitutes an admission for purposes of determining removability under INA 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii), as an alien convicted of an aggravated felony at any time after admission).

Matter of Chavez-Alvarez, 26 I. & N. Dec. 274 (BIA Mar. 14, 2014) (an sentencing enhancement element listed in a specification in the Manual for Courts-Martial, that must be pled and proved beyond a reasonable doubt, is the functional equivalent of an element of a criminal offense for immigration purposes).

Matter of C-J-H, 26 I. & N. Dec. 284 (BIA 2014) (noncitizen who has already adjusted status from asylee to LPR cannot re-adjust under INA 209(b), as a defense to removal).

Castillo v. Holder, 729 F.3d 296 (3d Cir. 2013) (state judicial disposition must be a conviction under INA 101(a)(48), , 8 U.S.C. 1101(a)(48), in order to trigger the criminal conviction bar to non-LPR cancellation of removal).