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In re Robles-Urrea

2 Analyses of this admin-law by attorneys

  1. Board Requests Amicus Briefs on Whether the Federal Offense of Misprision of a Felony is a CIMT

    The Law Offices of Grinberg & Segal, PLLCAlexander J. SegalFebruary 2, 2017

    In order for the offense to categorically qualify as a CIMT, any conviction under any provision of 18 U.S.C. 4 must constitute a CIMT. The language of 18 U.S.C. 4 is as follows:Whoever, having knowledge of the actual commission of a felony cognizable by a court of the United States, conceals and does not as soon as possible make known the same to some judge or other person in civil or military authority under the United States, shall be fined under this title or imprisoned not more than three years, or both.The Board is asking for briefs to address the issue in light of the following decisions:Matter of Robles-Urrea, 24 I&N Dec. 22 (BIA 2006) [PDF version];Robles-Urrea v. Holder, 678 F.3d 702 (9th Cir. 2012) [PDF version]; andItani v. Ashcroft, 298 F.3d 1213 (11th Cir. 2002) [PDF version].In the Matter of Robles-Urrea, the Board had held in 2006 that 18 U.S.C. 4 is a categorical CIMT.

  2. 7 Cir: Stop-time rule does not apply retroactively

    University of Denver Sturm College of LawOctober 23, 2014

    The BIA, following its longstanding precedent, concluded it did, thus Jeudy was statutorily ineligible for cancellation. Jeudy, slip op. at 2 (citing Matter of Robles-Urrea, 24 I&N Dec. 22, 27 (BIA 2006), and Matter of Perez, 22 I&N Dec. 689, 692-93 (BIA 1999) (en banc)).The Seventh Circuit came to the opposite conclusion.