Ala Rahim Yonan v. Todd Blanche

Summary

The court held that it had jurisdiction to review Yonan's challenge to the BIA's legal standard despite his criminal removability. It granted the petition, vacated the BIA's denial of Yonan's third motion to reopen, and remanded because the BIA evaluated changed country conditions against conditions arising after the 2008 merits hearing rather than against the 2008 baseline. Judge Nalbandian, dissenting, would have found that the BIA applied the correct standard and that any errors were harmless.