Lopez-Cardona v. Holder (9th Cir. 11/18/2011) The Ninth Circuit decided that residential burglary, specifically a violation of California Penal Code § 459, constitutes a crime of violence. Thus, a person convicted under this Penal Code section would become ineligible for relief under withholding of removal pursuant to 8 U.S.C. § 1231(b)(3). The court determined that […]