Hakim v. Holder, No. 09-60549

Convention Against Torture Immigration Case

In Hakim v. Holder, No. 09-60549, a petition for review of a Board of Immigration Appeals order finding that petitioner's money laundering conviction was for more than $10,000, and constituted a particularly serious crime under 8 U.S.C. section 1231(b)(3)(B)(ii), the court granted the petition where the BIA applied an incorrect legal standard in its Convention Against Torture consideration, and the case needed to be decided under an "actual knowledge" or "willful blindness" standard.

As the court wrote:  "Azmi Hakim seeks review of a Board of Immigration Appeals ("BIA") order finding that his money laundering conviction was for more than $10,000, and constituted a particularly serious crime under 8 U.S.C. § 1231(b)(3)(B)(ii). He further contends that the BIA applied an incorrect legal standard to find that he was not eligible for relief under the Convention Against Torture ("CAT"). We affirm the BIA holding that Hakim laundered more than $10,000, and that this constituted a particularly serious crime."

Related Resources

• Read the Fifth Circuit's Decision in Hakim v. Holder, No. 09-60549