17 Jul 2013
Unpub. BIA Remand on Ariz. Money Laundering: Matter of Ruiz-Estrada
"While we find no cause to disturb the Immigration Judge's analysis of the record of conviction for the purpose of determining whether the respondent's conviction involved the requisite level of "scienter," as discussed by the Attorney General in Matter of Silva-Trevino, 24 I&N Dec. 687 (A.G. 2008), we find that further proceedings are necessary to clarify the basis on which the Immigration Judge determined that the Arizona statute at issue reaches the type of "reprehensible conduct" necessary for a finding that an offense involved moral turpitude." - Matter of Ruiz-Estrada, July 11, 2013, unpub. [Hats off to Hugo F. Larios! And continuing thanks to Ben Winograd and IRAC for all the unpubs!]
