Rather, in each of the cases considered in Straker, and in Straker itself, there was a conviction that gave rise to mandatory detention. See Matter of West, 22 I. & N. Dec. at 1406; Matter of Kotliar, 24 I. & N. 3 The courts in Escrogin, Lora, and Masih deferred to the “released” analysis in Straker. Case 1:15-cv-02724-RA Document 10 Filed 05/18/15 Page 23 of 30 20 Dec. at 124; Matter of Rojas, 23 I. & N. Dec. at 117-18; Straker, 985 F. Supp. 2d at 348.