9th Circ. Upholds BIA False Imprisonment Removal Order

Law360 (November 19, 2019, 2:43 PM EST) -- The Ninth Circuit has denied a Micronesian man's challenge of a Board of Immigration Appeals removal order based on an unlawful imprisonment conviction, saying unlawful imprisonment is a crime that warrants removal.

Joseph Fugow’s 2014 conviction of first-degree unlawful imprisonment is a “crime involving moral turpitude,” or CIMT, that is a removal offense under the Immigration and Nationality Act, the panel said in an unsigned opinion Monday.

Though the INA doesn’t define what constitutes a CIMT and the Ninth Circuit hasn’t developed a clear standard for the term, by comparing Hawaii state law and federal law, the circuit court concluded that...

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