Ep. 160 - Precedential Decisions from 5/15/2023 - 5/21/2023 (Zipper Clause; asylum termination; Rwanda genocide; crime of violence; violent force; omission as force; VAWA; extreme cruelty; lack of physical abuse)

Mukantagara v. DHS, No. 21-4144 (10th Cir May 16, 2023)

• Zipper Clause; INA § 242(b)(9); termination of asylum status; Rwanda genocide 

USA v. Harris, No. 17-1861 (3d Cir. May 17, 2023) and USA v. Jenkins, No. 18-2222 (3d Cir. May 18, 2023) 

• Borden; recklessness; omission; violent force; first degree aggravated assault; robbery; Pennsylvania; 18 Pa. Cons. Stat. § 2702(a)(1); second-degree aggravated assault of a protected individual in violation of 18 Pa. Cons. Stat. § 2702(a)(3); realistic probability test

Ruiz v. U.S. Att’y Gen., No. 22-10445 (11th Cir. May 18, 2023)

• VAWA cancellation of removal; definition of extreme cruelty; Patel; reviewable hardship determination; no requirement for physical abuse; INA § 103(a)(1); quintessential question of law 

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