The Effect of Expungement on Removability of Non-Citizens

For most of the twentieth century, a non-citizen was generally not subject to removal on the basis of a criminal conviction which had been expunged by the state that rendered the conviction. During that time, the definition of a conviction for purposes of immigration law was borrowed from the law of the state which rendered the criminal conviction. In the Illegal Immigration Reform and Immigrant Responsibility Act (IRIRA) of 1996 Congress sought to provide a more uniform definition of the term conviction sufficient to justify an order of removal under the immigration law. The IIRIRA does not mention expungement, however. This Article argues that the Board of Immigration Appeals (BIA) and courts have misconstrued the IIRIRA. In 1999 the BIA first dealt with the effect of a state expungement under the statute. This Article argues that the BIA\u27s decision in Matter of Roldan improperly reversed more than a half-century of precedent by refusing to give effect to a state expungement of a non-citizen\u27s conviction unless expressly provided by federal statute. Judicial decisions have since accepted this rule. Part I of this Article reviews state expungement statutes. Part II summarizes cases prior to the IIRIRA. Part III explains the IIRIRA and Matter of Roldan. Part IV addresses recent cases concerning the effect of a state expungement on removability, arguing that these cases have either misconstrued the IIRIRA or improperly applied the Chevron doctrine. Part V compares the current state of the law with immigration laws abroad, arguing that the exceptional result reached by United States courts is further evidence that Matter of Roldan and its progeny are mistaken

The variable prevalence of bovine tuberculosis among dairy herds in Central Ethiopia provides opportunities for targeted intervention.

Bovine tuberculosis (bTB) is an important disease for dairy productivity, as well as having the potential for zoonotic transmission. Previous prevalence studies of bTB in the dairy sector in central Ethiopia have suggested high prevalence, however, they have been limited to relatively small scale surveys, raising concerns about their representativeness. Here we carried out a cross sectional one-stage cluster sampling survey taking the dairy herd as a cluster to estimate the prevalence of bTB in dairy farms in six areas of central Ethiopia. The survey, which to date is by far the largest in the area in terms of the number of dairy farms, study areas and risk factors explored, took place from March 2016 to May 2017. This study combined tuberculin skin testing and the collection of additional herd and animal level data by questionnaire to identify potential risk factors contributing to bTB transmission. We applied the single intradermal cervical comparative tuberculin (SICCT) test using >4mm cut-off for considering an individual animal as positive for bTB; at least one reactor animal was required for a herd to be considered bTB positive. Two hundred ninety-nine dairy herds in the six study areas were randomly selected, from which 5,675 cattle were tested. The overall prevalence of bTB after standardisation for herd-size in the population was 54.4% (95% CI 48.7-60%) at the herd level, and it was 24.5% (95% CI 23.3-25.8) at the individual animal level. A Generalized Linear Mixed Model (GLMM) with herd and area as random effect was used to explore risk factors association with bTB status. We found that herd size, age, bTB history at farm, and breed were significant risk factors for animals to be SICCT positive. Animals from large herds had 8.3 times the odds of being tuberculin reactor (OR: 8.3, p-value:0.008) as compared to animals from small herds. The effect of age was strongest for animals 8-10 years of age (the oldest category) having 8.9 times the odds of being tuberculin reactors (OR: 8.9, p-value:<0.001) compared to the youngest category. The other identified significant risk factors were bTB history at farm (OR: 5.2, p-value:0.003) and cattle breed (OR: 2.5, p-value: 0.032). Our study demonstrates a high prevalence of bTB in central Ethiopia but with a large variation in within-herd prevalence between herds, findings that lays an important foundation for the future development of control strategies

African Linguistics in Central and Eastern Europe, and in the Nordic Countries

Non peer reviewe

The Effect of Expungement on Removability of Non-Citizens

For most of the twentieth century, a non-citizen was generally not subject to removal on the basis of a criminal conviction which had been expunged by the state that rendered the conviction. During that time, the definition of a conviction for purposes of immigration law was borrowed from the law of the state which rendered the criminal conviction. In the Illegal Immigration Reform and Immigrant Responsibility Act (IRIRA) of 1996 Congress sought to provide a more uniform definition of the term conviction sufficient to justify an order of removal under the immigration law. The IIRIRA does not mention expungement, however. This Article argues that the Board of Immigration Appeals (BIA) and courts have misconstrued the IIRIRA. In 1999 the BIA first dealt with the effect of a state expungement under the statute. This Article argues that the BIA\u27s decision in Matter of Roldan improperly reversed more than a half-century of precedent by refusing to give effect to a state expungement of a non-citizen\u27s conviction unless expressly provided by federal statute. Judicial decisions have since accepted this rule. Part I of this Article reviews state expungement statutes. Part II summarizes cases prior to the IIRIRA. Part III explains the IIRIRA and Matter of Roldan. Part IV addresses recent cases concerning the effect of a state expungement on removability, arguing that these cases have either misconstrued the IIRIRA or improperly applied the Chevron doctrine. Part V compares the current state of the law with immigration laws abroad, arguing that the exceptional result reached by United States courts is further evidence that Matter of Roldan and its progeny are mistaken

African Linguistics in Asia and Australia

Asian and Australian institutions with a research focus on African languages are of fairly recent vintage. Japan has a strong academic infrastructure devoted to African linguistics, based in several universities and research centres. China looks back more than 50 years of interest in teaching Swahili and other major African languages, recently broadening the scope to encompass other issues of linguistic interest. In South Korea, teaching Swahili was also the precursor of more general African linguistics, allowing for regional specializations of researchers. In Australia, academic interest emerges with the increasing presence of experts on African languages and linguistics in the country