Bradley v. Attorney General of the U.S., 603 F.3d 235 (3d Cir. Apr. 22, 2010) (rejecting arguments that removal order is void under Woodby v. INS, 385 U.S. 276, 286 (1966), because the record lacks "clear, unequivocal, and convincing evidence" that noncitizen waived right to contest his removal under the Visa Waiver Program ("VWP"), 8 U.S.C.

Johnson v. United States Atty Gen., __ F.3d __ (3d Cir. Apr. 16, 2010) (court lacks jurisdiction to review discretionary determination on whether VAWA cancellation of removal applicant has shown that he suffered extreme cruelty inflicted by his spouse).

Kaplun v. Holder, 602 F.3d 260 (3d Cir. Apr. 9, 2010) (BIA erred in applying de novo review to determination of whether noncitizen would be tortured; BIA should have applied clearly erroneous standard).

Zegrean v. U.S. Attorney General, 602 F.3d 273 (3d Cir. Apr. 13, 2010) (noncitizen cannot establish prima facie eligibility for naturalization, under 8 C.F.R. 1239.2(f), when removal proceedings began before the naturalization application was filed), citing Perriello v. Napolitano, 579 F.3d 135 (2d Cir. 2009).

Benaouicha v. Holder, 600 F.3d 795 (7th Cir. Apr. 6, 2010) (noncitizen convicted of a crime of moral turpitude is ineligible for VAWA cancellation, even if good moral character can be shown).

Lee v. Holder, 599 F.3d 973 (9th Cir. Mar. 25, 2010) (Immigration Judge lacks jurisdiction to consider application for U-Visa interim relief).

Vila v. U.S. Attorney General, 598 F.3d 1255 (11th Cir. Mar. 10, 2010) (period during which noncitizen who entered without inspection was in United States, pursuant to approved I-140 visa and pending adjustment of status petition, could not be counted in determining the seven years lawful continuous residence prior to the initiation of removal proceedings).

Penn State Law and the Pennsylvania Immigration Resource Center recently issued a toolkit for practitioners on cancellation of removal for LPRs. The toolkit includes: 1) a summary of the statutory elements of LPR Cancellation of Removal; 2) sample exhibit lists, legal memos, and checklists; 3) litigation tips and strategies from practitioners across the country; and 4) a digest of dozens of relevant cases from the Board of Immigration Appeals and federal courts. http://law.psu.edu/academics/clinics_and_externships/center_for_immigran...

Ledezma-Garcia v. Holder, 599 F.3d 1055 (9th Cir. Mar. 22, 2010) (although the "aggravated felony" definition applies regardless of the date of conviction, an aggravated felony conviction occurring prior to November 18, 1988 does not trigger deportability under INA 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii)), overruling Matter of Lettman, 22 I. & N. Dec. 365 (BIA 1998) (en banc).

(1) During Removal Proceedings. The standard to qualify for voluntary departure prior to the completion of removal proceedings is less stringent than that for qualifying at the conclusion of proceedings.

Ledezma-Garcia v. Holder, 599 F.3d 1055 (9th Cir. Mar. 22, 2010) (although the "aggravated felony" definition applies regardless of the date of conviction, an aggravated felony conviction occurring prior to November 18, 1988 does not trigger deportability under INA 237(a)(2)(A)(iii), 8 U.S.C. 1227(a)(2)(A)(iii)), overruling Matter of Lettman, 22 I. & N. Dec. 365 (BIA 1998) (en banc).

In 1996, Congress enacted restrictions against judicial review of final removal orders for noncitizens "removable" for criminal grounds under INA 237(a)(2), including aggravated felony convictions.