In 2017, the Ninth Circuit Court of the United States decided a case of an undocumented noncitizen that went against United States Su- preme Court precedent. The appellant in Marinelarena v. Sessions was removed despite the fact that she had not been convicted of any crimes. This comment examines the arguments and strategies of the case that the judges relied upon in their opinion.
The Unanswered Conundrum: Inconclusive Record and the Burden of Proof for Immigration Relief,
Rich. Pub. Int. L. Rev.
Available at: https://scholarship.richmond.edu/pilr/vol21/iss2/11