Matter of Zorilla-Vidal

1 Analyses of this admin-law by attorneys

  1. BIA: Criminal Solicitation is CSO

    University of Denver Sturm College of LawMarch 21, 2009

    The BIA released a decision today holding that a Florida conviction for criminal solicitation for the delivery of cocaine is a controlled substance offense. Matter of Juan Carlos Zorilla-Vidal, 24 I&N Dec. 768 (BIA 2009).According to the BIA, “the respondent’s Florida conviction for soliciting the delivery of cocaine is a conviction for an offense under State law relating to a controlled substance that makes him removable from the United States under section 237(a)(2)((i) of the Act.”This case sounds like more bad news for anyone interested in arguing that a conviction for a drug-related offense is not a CSO.