Amicus brief to BIA (Aug. 2, 2017) — modified categorical approach and CIMTs (pro bono counsel Devin Theriot-Orr)
Amicus brief, Petitioner’s opening and reply briefs, Government’s brief, to Second Circuit (2017) — NYPL 1552.5, petit larceny, as CIMT; adjudicative retroactivity (pro bono counsel Richard Mark of Gibson Dunn for Petitioner; IDP for amici)
Amicus brief to BIA (Mar. 8, 2016) — 18 U.S.C. 4, misprision of a felony, as CIMT; adjudicative retroactivity (counsel IDP for amici)
Following a year marred by hateful violence and the escalation of a racist anti-immigrant agenda, we are re-energizing to expand the fight for a world defined by diversity, human rights, and justice for all.