Criminal

In immigration law the only valid reasons to overturn a conviction are Constitutional ones so where a State court order granting a respondent’s motion to vacate a conviction does not indicate the reason for the vacatur, and there is no other basis in the record to independently establish the reason, the respondent has not satisfied his burden to show that the court vacated his conviction because of a substantive or procedural defect in his criminal proceedings. AZRAG, 28 I&N Dec. 784 (BIA 2024).