Jennifer Koh’s Article Cited by Ninth Circuit

Jennifer Koh’s law review article, Crimmigration and the Void for Vagueness Doctrine, published by the Wisconsin law Review in 2016, has been cited by Judge Marsha Berzon of the Ninth Circuit Court of Appeals in a concurring opinion arguing for reconsideration of whether the “crime involving moral turpitude” definition in immigration law is unconstitutionally vague.  The decision in Aguirre-Barbosa v. Barr can be found here.

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Jennifer Koh’s Scholarship Cited in Published Decision by Ninth Circuit Court of Appeals

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)).