On January 10, Professor Jennifer Koh’s law review article, Removal in the Shadows of Immigration Court, 90 S. Cal. L. Rev. 181 (2017), was prominently cited in a published decision by Judge Paul Watford for the Ninth Circuit Court of Appeals. The case, Gomez-Velazco v. Sessions, involved a due process claim raised by a noncitizen who had been ordered deported pursuant to an administrative removal procedure under 8 U.S.C. 1228(b). The decision cited Professor Koh’s scholarship for the rise in streamlined removal proceedings that automatically deprive noncitizens of immigration court hearings, the critical role of lawyers in deportation matters, and the inherent complexity of removability determinations in immigration law. (The latter topic is also discussed in Professor Koh’s 2014 article, Rethinking Removability, 65 Fla. L. Rev. 1803 (2014)).