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Drug Trafficking found to be particularly serious crime

  1. The Fourth Circuit upheld the BIA and the IJ’s determination that the petitioner’s aggravated felony conviction for a drug trafficking crime, for which the petitioner received a sentence of five years’ imprisonment, was per se a particularly serious crime under INA §241(b)(3)(B). The court thus found that the petitioner was ineligible for withholding of removal.

BIA on the “one central reason” standard that applies to asylum and withholding of removal applications

BIA held that the “one central reason” standard that applies to asylum applications pursuant to INA §208(b)(1)(B)(i) also applies to applications for withholding of removal under §241(b)(3)(A). Matter of C-T-L, 25 I&N Dec. 341 (BIA 2010).

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