The court found that the BIA had reviewed the immigration judge’s factual findings, used to grant the petitioner’s request to defer removal, under a de novo standard of review instead of under the required clearly erroneous standard.
https://atomic-temporary-10880024.wpcomstaging.com/tag/bia-2/
https://atomic-temporary-10880024.wpcomstaging.com/tag/bia-board-of-immigration-appeals/
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https://californiaimmigration.us/bia-deference-given-to-particulary-serious-crime/
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Brian D. Lerner Immigration Attorney & Deportation Lawyer Blog 
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