Urias-Orellana v. Bondi · ¶35

Just a few years after we decided Elias-Zacarias, Congress passed the Illegal Immigration Reform and Immigrant Responsibility Act of 1996 (IIRIRA), amending several provisions of the INA governing judicial review. § 306(a)(2), 110 Stat. 3009–607. Among other things, IIRIRA added § 1252(b)(4), clarifying the relevant standards of review for IJ and BIA removal orders. But § 1252(b)(4) did not depart from our decision in Elias-Zacarias. To the contrary, § 1252(b)(4) stayed the course.

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