Saturday, May 26th, 2018

BIA Applies Brand X: Matter of M-H-, ID3772

The holding in Matter of N-A-M-, 24 I&N Dec. 336 (BIA 2007), that an offense need not be an aggravated felony to be considered a particularly serious crime for purposes of barring asylum or withholding of removal, should be applied to cases within the jurisdiction of the United States Court of Appeals for the Third Circuit. – Matter of M-H-, Int. Dec. 3772, 26 I&N Dec. 46 (BIA 2012)