Gao v. Holder
Gao v....(U.S. 4th Cir., Administrative Law, Criminal Law & Procedure, Government Law, Immigration Law) BIA’s denial of Chinese petitioner’s applications for withholding of removal and asylum based on her conviction for unlawful export of technology to China is affirmed where: 1) an offense need not be an aggravated felony to qualify as a particularly serious crime for purposes of withholding; and 2) the BIA may determine that a non-aggravated felony is a particularly serious crime for purposes of asylum through the process of case-by-case adjudication.