July 29 , 2008

Selected Articles - Recent Cases

Contents:

1. Article: Divisible Statute Analysis - Reasonable Probability of Prosecution
2. 2008 Fall Seminar Series
3. Article: Removal Roceedings - Right to Impartial Immigration Judge - Judge Improperly Acting as Prosecutor - Due Process
4. New 2008 edition of Tooby's Crimes of Moral Turpitude now available!
5. Recent Developments
6. Tooby's Guide to Criminal Immigration Law Now Available!
   

---

Article: Divisible Statute Analysis - Reasonable Probability of Prosecution

     Traditionally, if consultation of the record of conviction did not establish that the defendant was convicted of a charge that invariably involved moral turpitude, the conviction would be presumed not to involve moral turpitude where the government bore the burden of proof. However, the United States Supreme Court recently made a statement that might be interpreted to suggest the noncitizen must also show a realistic probability that the state in fact prosecutes defendants for offenses that factually would fall outside the ground of deportation, instead of merely imagining a set of facts that would arguably fall within the crime but outside the ground of deportation.

     As a result, immigration authorities may require the noncitizen to show a realistic probability of prosecution under the state statute for conduct that falls outside the ground of deportation. The paragraph giving rise to this issue arose in the aggravated felony context, where a specific aggravated felony category may be defined by a "generic" definition of the terms used, the Supreme Court stated:

Moreover, in our view, to find that a state statute creates a crime outside the generic definition of a listed crime in a federal statute requires more than the application of legal imagination to a state statute's language. It requires a realistic probability, not a theoretical possibility, that the State would apply its statute to conduct that falls outside the generic definition of a crime. To show that realistic possibility, an offender, of course, may show that the statute was so applied in his own case. But he must at least point to his own case or other cases in which the state courts in fact did apply the statute in the special (nongeneric) manner for which he argues.

In James v. United States, the Supreme Court further expanded on this point in the context of determining whether attempted burglary qualified as on offense posing a "serious potential risk" of physical injury for purposes of the Armed Career Criminal Act. Citing Duenas-Alvarez, the court announced:

We do not view that approach as requiring that every conceivable factual offense covered by a statute must necessarily present a serious potential risk of injury before the offense can be deemed a violent felony. . . . Rather, the proper inquiry is whether the conduct encompassed by the elements of the offense, in the ordinary case, presents a serious potential risk of injury to another. One can always hypothesize unusual cases in which even a prototypically violent crime might not present a genuine risk of injury-for example, an attempted murder where the gun, unbeknownst to the shooter, had no bullets, see United States v. Thomas, 361 F.3d 653, 659 (C.A.D.C.2004). Or, to take an example from the offenses specifically enumerated in § 924(e)(2)(B)(ii), one could imagine an extortion scheme where an anonymous blackmailer threatens to release embarrassing personal information about the victim unless he is mailed regular payments. In both cases, the risk of physical injury to another approaches zero. But that does not mean that the offenses of attempted murder or extortion are categorically nonviolent.

     Although counsel could argue that James applies in the context of determining whether a "risk" exists (as in 18 U.S.C. § 16(b) crime of violence cases), a number of courts have already cited this language in connection with Duenas-Alverez as applied to other grounds of removal.

     Duenas-Alvarez and James could be said to be announcing two new tests - first allowing courts to look to the realistic probability that the state would apply the statute at issue to prosecute the conduct that falls outside the ground of deportation, as opposed to examining the minimum conduct punishable under the statute, and second, allowing the courts to ask only whether the ordinary and usual matter of commission of the offense would fall within a ground of removal, rather than requiring the court to examine the full range of conduct punished. This interpretation would alter the categorical analysis announced by Taylor, and reaffirmed by Shepard, without any discussion justifying such a wide-scale change in the law. In Duenas, however, the Supreme Court expressly reaffirmed and applied the normal categorical and modified categorical analysis, so this interpretation would not seem to be justified.

     The Fifth and Ninth Circuits have taken different approaches to applying these cases. The Fifth Circuit appears to take a very narrow view -- requiring the noncitizen or defendant to provide either personal evidence (from his or her own case) or case law showing that the statute of conviction reaches conduct that falls outside the definition of the ground of deportation. In United States v. Ramos Sanchez, the court rejected the contention that an indecent solicitation statute at issue was overbroad because it could be used to prosecute a minor. Even though the statute at issue had been used to prosecute a 17-year-old for having sex with his 15-year-old girlfriend, the court found that case inapplicable, since the age of consent in Kansas was 16. The Fifth Circuit has also applied the James "ordinary and usual matter" test.

     On the other hand, the Ninth Circuit does not require the noncitizen to provide "specific examples" of a state prosecuting people "for acts that would fall outside the generic definition of crimes of moral turpitude." Rather the court stated that:

The issue is not whether in some cases violators of section 32 have been involved in a crime of moral turpitude. The issue is whether everyone prosecuted under that section has necessarily committed a crime involving moral turpitude. There is nothing inherent in the crime of accessory after the fact that makes it a crime involving moral turpitude in all cases.

Likewise, in finding that the California offense of leaving the scene of an accident resulting in bodily injury was not a crime of moral turpitude, the Ninth Circuit found that looking to the statutory language, "a driver in an accident resulting in injury who stops and provides identification, but fails to provide a vehicle registration number, has violated the statute." The court then rejected the DHS's argument that such an offense would not be prosecuted:

We cannot . . . ignore the plain language of § 20001(a). Duenas-Alvarez does caution us against "conjur[ing] up some scenario, however improbable, whereby a defendant might be convicted under the statute in question even though he did not commit the act encompassed by the federal provision." United States v. Carson, 486 F.3d 618, 610 (9th Cir. 2007) (per curiam). But where, as here, the state statute plainly and specifically criminalizes conduct outside the scope of the federal definition, we do not engage in judicial prestidigitation by concluding that the statute "creates a crime outside the generic definition of a listed crime." Duenas-Alvarez, 127 S.Ct. at 822.

Other courts may also follow this analysis.

     The Ninth Circuit is clearly right in holding that where non-deportable conduct falls within the plain language of the statute defining the criminal offense, no more proof is required. United States v. Grisel, 488 F.3d 844, 850 (9th Cir.2007) (en banc) (noncitizen need not meet Duenas realistic probability of prosecution test for crimes where "a state statute explicitly defines a crime more broadly than the generic definition"). If the immigration court, however, insists on proof of a reasonable probability of prosecution, counsel can attempt to provide it by the following means:

     (1) Judicial decisions of the state of conviction showing prosecutions for conduct falling outside the ground of deportation would also clearly be sufficient.

     (2) Unpublished decisions are equally probative of this point, since they reflect actual prosecutions for non-deportable conduct. Vizcarra-Ayala v. Mukasey, 514 F.3d 870 (9th Cir. Jan. 23, 2008) (court of appeals cites unpublished California decisions to show that forgery is in fact prosecuted on the basis of genuine documents falling within the statutory definition of the state offense).

     (3) Moreover, counsel can examine pattern jury instructions. If non-deportable conduct falls within them, it is very hard for the government to argue there is no realistic probability of prosecution, since every jury in every prosecution for violating that statute is instructed to convict, under the statute, for the non-deportable conduct.

     (4) Counsel could also offer an affidavit of a state prosecutor or defense attorney as to the state's practices.

This article is drawn from N. Tooby, J. Rollin & J. Foster, Crimes of Moral Turpitude § 6.6(C) (3d ed. 2008)(forthcoming).

---

2008 Fall Seminar Series
National Day-long Crimes and Immigration Trainings

Upcoming Events:

Saturday, September 13, 2008
New York University School of Law
Furman Hall, Room 216
245 Sullivan St.
New York, NY 10012
Norton Tooby & Dan Kesselbrenner
9:00 am - 5:00pm
REGISTER FOR THIS SEMINAR

Topics:

I. New Developments in Drug Trafficking Aggravated Felonies
II. Resisting Attacks on Categorical Analysis
III. Fraud and Tax Aggravated Felonies
IV. Sexual Abuse of a Minor Aggravated Felonies

California Crimes and Immigration Seminars

Saturday October 25, 2008
San Francisco, CA
Norton Tooby & Kathy Brady
9:00am - 5:00pm

Saturday November 8, 2008
Los Angeles, CA
Norton Tooby & Kathy Brady
9:00am - 5:00pm

* All Premium Members obtain a 15% discount on seminar registrations and books!

For more information, please visit our website at: www.NortonTooby.com

---

Article: Removal Roceedings - Right to Impartial Immigration Judge - Judge Improperly Acting as Prosecutor - Due Process

     Immigration counsel can argue that reversal of a removal order is required when an immigration judge plays an improper prosecutorial role in the proceedings. When the judge abandons his or her role as an unbiased arbiter of fact and law, and becomes a prosecutor, the court contravenes its responsibilities as a neutral fact finder. It is well settled that a judge must remain neutral. Marshall v. Jerrico, Inc., 446 U.S. 238 (1980). See also Schweiker v. McClure, 456 U.S. 188 (1982) (hearing officers serving in a quasi-judicial capacity must meet the due process demand of impartiality). The Immigration Court's decision should be reversed if the record clearly demonstrates that the judge played a prosecutorial role outside the scope of the court's responsibility as an unbiased trier of fact and law. The judge clearly acts as an aggressive prosecutor it s/he attempts to establish that the Respondent was guilty of a crime. The Immigration Judge further exhibits a prosecutorial tendency by examining respondent as if the court were a tax official suspecting violations of the Internal Revenue laws. The judge also demonstrates bias by subjecting respondent to "post-trial" examinations which merely reiterate the questioning previously conducted regarding the arrest, his educational background, his student loans and his tax returns. The Court of Appeals for the Ninth Circuit chastised an Immigration Judge who exhibited bias and prejudice during removal hearings by abandoning her neutrality in violation of due process. Reyes-Melendez v. INS, 342 F.3d 1001 (9th Cir. 2003). The Court reasoned that "very early in the hearing, the IJ took over direct examination ... [and] the IJ noticeably became aggressive . . . ." (Id. at 1007.) The Immigration Judge may rely on Yang v. McElroy, 277 F. 3d 158 (2d Cir. 2002), to justify his or her role as fact-finder, but there are clearly limitations on the manner in which s/he may appropriately develop the record, especially when the respondent is represented by counsel. (See United States v. Copeland, 376 F.3d 61, 71 (2d Cir. 2004) (explaining that an Immigration Judge has the same duty to develop the record as the administrative law judge in a social security case, especially when the litigant is pro se and concluding the removal system "relies on [the Immigration Judge] to explain the law accurately to pro se aliens"); Secaida-Rosales, supra, at 306, citing Qiu v INS, supra, at n.17 (recognizing the court has not distinctly defined the Immigration Judge's role in developing in the record when an alien is represented by counsel). Stated succinctly by the Seventh Circuit, "discretion is bounded by the applicant's right to receive a fair hearing." (Podio v. INS, 153 F.3d 506, 509 (1998).) In Podio, the judge frequently interrupted and took over the questioning of the respondent. The judge in this case oversteps his bounds as did the judges in Reyes-Melendez and Podio. The Second Circuit has considered the limitations on a judge's power to control deportation proceedings by ruling that a respondent had not effectively waived his right to counsel, allowing the judge to go forward on the merits of an application for relief, even if the respondent had been given a single two week continuance by the Immigration Court to locate an attorney. (Montilla v. INS, 926 F.2d 162 (2nd Cir. 1991).) Thanks to Sophie Feal. See also Cuko v. Mukasey, infra.

---

	Tooby's Crimes of Moral Turpitude (2008) 3d edition. Fully indexed, useful in all jurisdictions, up-to-the-minute and expanded. 800 pages. $24
	-Updated through 3/1/08 -Includes all immigration decisions defining CMTs -Useful in all jurisdictions -Comprehensive and fully indexed To place an order, please visit our website at www.NortonTooby.com

Recent Developments

UNITED STATES SUPREME COURT -- POST CON RELIEF - GROUNDS - VIENNA CONVENTION
Medellin v. Texas, ___ U.S. ___, 2008 WL 762533 (Mar. 25, 2008) (neither an International Court of Justice case, Case Concerning Avena and Other Mexican Nationals (Mex. v. U. S.), 2004 I. C. J. 12, nor a memorandum issued by the President of the United States constitutes directly enforceable federal law that pre-empts state limitations on the filing of successive habeas petitions, affirming dismissal of a habeas petition in a death penalty case raising a claim that petitioner was not informed of his Vienna Convention right to notify the Mexican consulate of his detention).

FIRST CIRCUIT -- REMOVAL PROCEEDINGS - IMPARTIAL JUDGE - PROSECUTORIAL QUESTIONING OF RESPONDENT
Cuko v. Mukasey, ___ F.3d ___ (1st Cir. Mar. 31, 2008) (petition for review granted because IJ improperly assumed role of a government attorney by engaging in "prosecutorial questioning").See CD:15.25.

SECOND CIRCUIT -- RECORD OF CONVICTION - DISMISSED COUNTS -- FACTS CHARGED IN INDICTMENT NOT PART OF RECORD OF CONVICTION
James v. Mukasey, ___ F.3d ___, 2008 WL 763158 (2d Cir. Mar. 25, 2008) ("We reminded the District Court that "[f]actual matters considered as a basis for sentence must have some minimal indicium of reliability beyond mere allegation," and that "an indictment is not meant to serve an evidentiary function. Its primary purpose is to acquaint the defendant with the specific crime with which he is charged...." Id. at 701 (internal quotations marks omitted) (alteration in original). In this case, the IJ and BIA relied upon a factual allegation in the charging instrument -- that James had sexual intercourse with a sixteen-year-old when he was twenty-two -- to conclude that James was convicted of sexual abuse of a minor. But this factual allegation was not "actually and necessarily pleaded" to in order to establish the elements of endangering the welfare of a child.").

SECOND CIRCUIT -- JUDICIAL REVIEW - REMOVAL PROCEEDINGS - DENIAL OF RIGHT TO COUNSEL OF CHOICE IS A VIOLATION OF DUE PROCESS
Waldron v. INS, 17 F.3d 511 (2d Cir. 1993), cert. denied, 513 U.S. 1014 (1994) (Immigration Judge errs by disqualifying respondent's chosen counsel from representing the respondent, which is a per se violation of due process in the Second Circuit, regardless of whether prejudice is shown), citing Montilla v. INS, 926 F.2d 162 (2d Cir. 1991); see Matter of Santos, 19 I. & N. Dec. 103 (BIA 1984); Reno v. Flores, 507 U.S. 292, 306 (1993) (Fifth Amendment entitles noncitizen to due process of law in deportation proceedings).

FIFTH CIRCUIT -- AGGRAVATED FELONY - FRAUD OFFENSE - THEFT OFFENSE -- FRAUD AND THEFT HAVE DIFFERENT DEFINITIONS, SUGGESTING CONGRESS DID NOT INTEND ANY OVERLAP
Martinez v. Mukasey, ___ F.3d ___ (5th Cir. Mar. 11, 2008) ("We must assume that, by giving separate definitions to offenses "involving fraud and deceit" and "theft", Congress intended them to be different. See, e.g., United States v. Nordic Village, 503 U.S. 30, 36, 112 S.Ct. 1011, 117 L.Ed.2d 181 (1992). In this regard, we are mindful not to construe a definition within § 101(a)(43) to be "so broad that it is inconsistent with its accompanying words, thus giving unintended breadth to the [INA]". Gustafson, 513 U.S. at 575, 115 S.Ct. 1061 (quoting Jarecki v. G.D. Searle & Co., 367 U.S. 303, 81 S.Ct. 1579, 6 L.Ed.2d 859 (1961)) (internal quotation marks omitted)."). CD:19.73, 19.94;AF:5.55, 5.78

FIFTH CIRCUIT -- STATUTORY INTERPRETATION -- RULE OF LENITY - APPLIES TO EXCLUSION QUESTION
Martinez v. Mukasey, ___ F.3d ___ (5th Cir. Mar. 11, 2008) ("Here, defining "admitted", as used in § 212(h), to exclude adjustment to LPR status subsequent to entry, as was done by Martinez, is bolstered by the "longstanding principle of construing any lingering ambiguities in deportation statutes in favor of the alien". Cardoza-Fonseca, 480 U.S. at 449, 107 S.Ct. 1207 (citations omitted). This canon of construction, comparable to the rule of lenity in criminal cases, is based on the drastic nature of removal. "We will not assume that Congress meant to trench on [the alien's] freedom beyond that which is required by the narrowest of several possible meanings of the words used." Fong Haw Tan v. Phelan, 333 U.S. 6, 10, 68 S.Ct. 374, 92 L.Ed. 433 (1948). Therefore, this rule of narrow construction provides an additional basis to construe § 212(h) in favor of Martinez being able to seek a waiver of inadmissibility."). CD:16.38;AF:4.41;CMT:6.7;SH:5.25

SEVENTH CIRCUIT -- RELIEF - 212(H) WAIVER - 30 GRAM MARIJUANA EXCEPTION - DRUG PARAPHERNALIA
Escobar-Barraza v. Mukasey, ___ F.3d ___, 2008 WL 656897 (7th Cir. Mar. 13, 2008) (noncitizen qualified for a waiver of inadmissibility, under INA § 212(h), 8 U.S.C. § 1182(h), on account of a controlled substances conviction, since his conviction for possession of drug paraphernalia related to a single offense of simple possession of 30 grams or less of marijuana). CD:24.29, 21.35;AF:2.45;CMT:3.44;SH:7.144

EIGHTH CIRCUIT
REMOVAL PROCEEDINGS - MENTAL COMPETENCY
Mohamed v. Tebrake, 371 F.Supp.2d 1043 (D. Minn. 2005) (IJ must inquire as to respondent's mental competency, or 8 CFR § 1240.4 would be a nullity, and it was an abuse of discretion not to inquire where person was in a mental hospital and hearing was held via circuit television).

EIGHTH CIRCUIT -- IMMIGRATION OFFENSES - SOCIAL SECURITY CARD IS NOT AN IDENTIFICATION CARD
United States v. Murillo, ___ F.Supp.2d ___, 2008 U.S. Dist. LEXIS 19568 (N.D. Iowa Mar. 13, 2008) (a "social security card" does not constitute a "means of identification" within the meaning of 18 U.S.C. § 1546(b) and 8 U.S.C. § 1324a(b), so the court grants defendant's motion to dismiss Count 3); United States v. Tyson Foods, Inc., 258 F. Supp. 2d 809 (E.D. Tenn. 2003) (a "social security card" is not a "means of identification" within the meaning of 18 U.S.C. § 1546(b), even if this creates a "loophole" or appears inconsistent with 18 U.S.C. § 1546(a)).

NINTH CIRCUIT -- CD:20.6;CMT:8.6, 9.26, 9.39, 9.66, CHART
CRIME OF MORAL TURPITUDE - FALSE STATEMENT - FALSE IDENTIFICATION TO POLICE OFFICER
Blanco v. Mukasey, 518 F.3d 714 (9th Cir. Mar. 3, 2008) (California conviction of providing false identification to a police officer, in violation of Penal Code § 148.9(a), is not categorically a crime involving moral turpitude, under INA § 212(a)(2), 8 U.S.C. § 1182(a)(2), because the offense does not require fraudulent intent under California law).

NINTH CIRCUIT -- RELIEF - WAIVERS - 212(C) RELIEF - NINTH CIRCUIT TO REHEAR ABEBE ON MATTER OF BLAKE ISSUE
The Ninth Circuit ordered that Abebe v. Gonzales, 493 F.3d 1092 (9th Cir. 2007) be reheard en banc. In Abebe, a panel of the Ninth Circuit upheld the BIA's decision in Matter of Blake, 23 I. & N. Dec. 722 (BIA 2005) (finding a person convicted of sexual abuse of a minor is ineligible for a 212(c) waiver). The BIA had reasoned that the aggravated felony ground of removal had no statutory counterpart in the INA § 212(a) grounds of inadmissibility, so INA § 212(c) could not waive deportation on account of the conviction. CD:24.28;AF:2.44;CMT:2.43

TENTH CIRCUIT -- AGGRAVATED FELONY - CRIME OF VIOLENCE
United States v. Rodriguez-Enriquez, __ F.3d __, 2008 WL 624433 (10th Cir. Mar. 10, 2008) (Colorado conviction for assault two (drugging a victim), in violation of Colo.Rev.Stat. Ann. § 18-3-203(1)(e) (2001), is not a crime of violence for illegal re-entry sentencing purposes, since drugging by surreptitious means does not involve the use of physical force). CD:19.38;SH:7.46, 8.10;AF:5.19, A.14, B.9, B.5

STATUTES -- POST CON RELIEF - GROUNDS - STATE ADVISAL STATUTES
As of March, 2008, 28 states have adopted court rules or statutes that require the court, at plea, to advise the defendant concerning possible immigration consequences. Alas.R.Crim.P. 11(c)(3)(C); Arizona Rules of Court, rule 17.2(f) (2004); Ark. Rules of Court, rule 17.2(f)(2004); Cal. Penal Code § 1016.5 (West 1995); Conn. Gen. Stat. Ann. § 54-1j (West 1994); D.C. Code Ann. § 16-713 (West 1994); Fla. R. Crim. P. 3.172(8) (West 1995); Ga. Code Ann. § 17-7-93 (1997); Haw. Hawaii Stat. Ann. §§ 802E(1), (2), (3) (West 1994); Id. Crim. Rule. 11(d)(1); Ill. Comp. Stat. 5/113-8 (2006); Iowa R. Crim. Proc. 2.8(2)(b)(2005); Me. R. Crim. P. 11(b)(5) (West 2002); Md. R. 4-242(e) (Michie 2001); Mass. Gen. Laws Ann. ch. 278, §29D (West 1994); Minn. Rule Crim. Proc. 15.01(10)(c) (2000); Mont. Code Ann. § 46-12-210(1)(f) (1997); Neb. Rev. St. §29-1819.02 (West 2003); N.M. Dist. Ct. R.Cr.P. 5-303(E)(5) (1992); N.Y. Crim. Proc. Law § 220.50 (7) (McKinney 2001 Cum. Supp. Pamphlet); N.C. Gen. Stat. § 15A-1022 (a)(7) (West 1994); Ohio Rev. Code Ann. § 2943.031 (West 1989); Ore. Rev. Stat. § 135.385 (2)(d) (1997); R.I. Gen. Laws § 12-12-22 (West 2003); Tex. Code Crim. Proc. Ann. art. 26.13(a)(4) (West 1994); 13 S.A. § 6565; Wash. Rev. Code Ann. § 10.40.200 (West 1995); Wis. Stat. §§ 971.08(1)(c), (2) (West 1994).

CD:6.11
STATISTICS - IMMIGRATION HOLDS
Mar. 28, 2008
The head of Imigration and Customs Enforcement, Julie L. Myers, announced to the House Appropriations Committee that at least 304,000 immigrant criminals eligible for deportation are behind bars nationwide. The annual number of deportable immigrant inmates was expected to vary from 300,000 to 455,000, or 10 percent of the overall inmate population, for the next few years. She said DHS intended to speed the deportation of immigrants convicted of the most serious crimes by linking state prisons and county jails into federal databases that combine FBI fingerprint files with DHS immigration, border and antiterrorism records. In fiscal 2007, ICE statistics indicate 164,000 immigrant inmates were charged in removal proceedings with immigration violations to prepare the way for deportation, and 95,000 immigrants with criminal histories were deported.

RESOURCES - IMMIGRATION ADVOCATES NETWORK - LEGAL INFORMATION
For a wonderful new website, with valuable resources on criminal immigration law, among other topics, see http://www.immigrationadvocates.org/

RELIEF - NATURALIZATION - TERMINATING REMOVAL PROCEEDINGS TO PURSUE NATURALIZATION BEFORE DHS
AILF Practice Advisory sets out arguments to challenge Matter of Acosta Hidalgo, a recent BIA decision holding that IJs and the BIA lack jurisdiction to determine prima facie eligibility for naturalization in order to terminate removal proceedings.

http://www.ailf.org/lac/pa/Acosta_Hidalgo_lac_pa_031808.pdf

---

	Tooby's Guide to Criminal Immigration Law (2008) - Simple strategies for criminal and immigration lawyers to work together in criminal cases to prevent deportation. Only $45
	- Short, simple, easy to understand - 200 pages - How we can protect defendants' immigration status, stage by stage in a criminal case - Summarizes the 2000-page Criminal Defense of Immigrants - Useful in any jurisdiction - Well organized to save hours of research

Praise for Mr. Tooby's Work:

"Essential."
- Dan Kesselbrenner, National Immigration Project of the National Lawyers Guild, Boston, MA

"The definitive resource."
- Ann Benson, Washington Defenders Immigration Project, Seattle, WA

"Intelligent strategies and practical tips."
- Kathy Brady, Immigration Legal Resource Center, San Francisco, CA

To place an order, please visit our website at www.NortonTooby.com.

Questions? Call (510) 601-1300

America's leading source of legal information on the overlap of criminal and immigration law.
We offer quality law books and seminars for criminal and immigration lawyers.
Legal information online anytime. 24 hours a day.