Yi Long Yang v. Alberto R. Gonzales, 1 United States Attorney General

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that ineffective assistance claims are forfeited absent “substantial compliance” with Lozada requirements
• excusing compliance where an IJ explicitly relied on counsel’s competence and counsel was disbarred shortly after the hearing for “truly shocking disregard” for his clients
• remanding absent 13 compliance with Lozada requirements where counsel had been disbarred for “truly 14 shocking disregard for his clients”
• finding error when BIA failed to acknowledge disbarment of former attorney because it was “too important to ignore” (quotation marks omitted)
• “Lozada requirements . . . provide a basis for determining whether counsel’s assistance was in fact ineffective.” (quotation marks omitted)
• record plainly showed IJ’s reliance on counsel’s competence and counsel’s subsequent “disbar[ment] for malpractice as an immigration attorney”

Source: CourtListener parenthetical corpus (CC0).