(A thoughtful, detailed analysis of Judulang is available here.) The Supreme Court in Judulang expressly rejected the foundations of the statutory counterpart rule, rooted in an earlier Attorney General precedent, Matter of Hernandez-Casillas, 20 I&N Dec. 262 (BIA 1990; A.G. 1991). In defending its position before the Supreme Court in Judulang, the U.S. government relied on the Attorney General’s formulation of § 212(c) in Hernandez-Casillas.