POPULARITY
Categories
Barrie v. U.S. Att'y Gen., No. 24-12504 (11th Cir. Feb. 19, 2026) aggravated felony rape definition; statutory interpretation; rule against superfluity; review of comparable federal statutes; attempted sexual abuse in violation of D.C. Code § 22-3002(a)(1); digital penetration Matter of L-S-C-R-, 29 I&N Dec. 451 (BIA 2026) remand for biometrics checks; interests of finality; 8 C.F.R. § 1003.47(h) Matter of F-B-A-, 29 I&N Dec. 456 (BIA 2026) failure to report harm; C-G-T-; conversion from Islam to Russian Orthodox Church; reasonable relocation; unable or unwilling; acquiesce, relocation, and CAT Irias v. Bondi, No. 25-1419 (8th Cir. Feb. 17, 2026) in absentia motion to reopen based on ineffective assistance of counsel; self reporting IAC; strict Lozada compliance Cante Mijangos v. Bondi, No. 25-1267 (1st Cir. Feb. 18, 2026) issue exhaustion; sexual abuse type asylum claim; nexus Khanal v. Bondi, No. 14-1572 (1st Cir. Feb. 18, 2026) asylum, withholding, and CAT grant despite adverse credibility; failure to consider evidence; credible death threats; Maoist extortion; Nepal Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!The Pen and SwordClick me!Discount code: ImmigrationReview26 Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
Witam Państwa, nazywam się Jarosław Drożdż, pracuję w Centralnym Szpitalu Klinicznym Uniwersytetu Medycznego w Łodzi, skąd nagrywam podcast Kardio Know-How. W tym odcinku omawiam najnowsze statystyki kardiologiczne z AHA. Jak co roku pod koniec stycznia analizuję najnowsze dane dotyczące chorób sercowo-naczyniowych, które omawiam także w podcaście Kardio-Know-How. Do 2016 r. korzystałem głównie z amerykańskiego raportu publikowanego w Circulation, a od kilku lat, jako konsultant wojewódzki, współtworzę również polskie zestawienia. W 2024 r. pod kierunkiem prof. Waldemara Banasiaka opublikowaliśmy pierwszy ogólnopolski raport konsultantów obejmujący dane za cały rok – dostępny tutaj: https://journals.viamedica.pl/polish_heart_journal/article/view/108435https://journals.viamedica.pl/polish_heart_journal/article/view/108484Tegoroczny raport amerykański pokazuje spadek liczby zgonów sercowo-naczyniowych do 916 tys., czyli o 26 tys. mniej niż rok wcześniej. Dla porównania: nowotwory odpowiadają za 680 tys. zgonów rocznie w USA, wypadki za 200 tys., udary za 160 tys., a przewlekłe choroby płuc za 145 tys. Umieralność kobiet i mężczyzn spadła w podobnym stopniu – uratowano około 15 tys. osób z każdej grupy w ciągu jednego roku. Jednocześnie tylko 1/4 dorosłych Amerykanów ma wystarczającą aktywność fizyczną, połowa ma nadciśnienie, a 90% spełnia kryteria zespołu sercowo-nerkowo-metabolicznego. Choć hospitalizacje z powodu choroby wieńcowej spadły dwukrotnie w ciągu 20 lat, liczba zgonów z powodu niewydolności serca wzrosła o 33%.Pełny raport AHA dostępny jest tutaj: https://www.ahajournals.org/doi/10.1161/CIR.0000000000001412, a dodatkowe dane (także europejskie) tutaj: https://www.heart.org/en/about-us/heart-and-stroke-association-statisticsSzczegółowy TRANSKRYPT do odcinka.Podcast jest przeznaczony wyłącznie dla osób z profesjonalnym wykształceniem medycznym.
(WATCH THIS EPISODE ON YOUTUBE) "Everybody in the art world thinks he's telling the truth, and thinks I'm crazy, but people outside of the art world are skeptical… I know why he [disavowed the painting]. He did it because he can't draw. Everything he does is projected, and he sketches it from the picture…This painting we have proves it." Described as one of the "most bizarre art authentication trials in recent memory," Reb unpacks (paints?) Fletcher v. Doig (7th Cir. 2025).*** MERCH STORE IS LIVE! Shop Reb Masel and Rebuttal Pod merch: https://rebmasel.shop/ CLICK HERE to PREORDER Reb's book: The Book They Throw At You—A Sarcastic Lawyer's Guide* To The Unholy Chaos of Our Legal System, *God No, Not Actual Legal Advice *** Follow @RebuttalPod on Instagram and Twitter! Follow @Rebmasel on TikTok, Instagram, and Twitter! *** 00:00 - Intro 01:10 - Case begins 04:18 - What has Peter Doig done? 08:18 - Plaintiffs' counsel is not a quitter 10:34 - OTHER ARTISTS WHO DISAVOWED THEIR WORKS 13:02 - PETER'S LEGAL BUDGET IS HUGE 19:02 - Meanwhile, the Plaintiffs..... 29:39 - U.S. ART MARKET IS THE WILD WEST OF THE LAW 36:47 - What is money laundering, again? 40:29 - TRIAL OUTCOME 29:35 - The sanctions were HOW MUCH?! 51:17 - Reb's Rebuttal Learn more about your ad choices. Visit megaphone.fm/adchoices
Rene Lopez v. Bondi, No. 24-1208 (4th Cir. Feb. 13, 2026) derivative citizenship; former INA § 321(a); establishing paternity through legitimation; Loper Bright; statutory interpretation; affirmative acts to establish paternity; Riley; petition for review despite CAT remand Matter of Jin, 29 I&N Dec. 441 (BIA 2026) marriage fraud; annulment; revoking I-130 petition; BIA appeal two-years late; deposition transcripts; two-year untimely appeal Buenrostro-Mendez, et al. v. Bondi, et al., No. 25-20496 (5th Cir. Feb. 6, 2026) mandatory detention for all EWIs; redundant and superfluous statutory interpretation; Hurtado; seeking admission; INA § 235(a)(2)(B); Laken Riley Act Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!The Pen and SwordClick me!Discount code: ImmigrationReview26 Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
Episode 100 In Part 2 of Domestic Detonation, we move deeper into the investigation and unravel how a domestic violence case escalated into a coordinated bombing plot that nearly claimed multiple lives. As investigators began connecting the devices, forensic evidence and witness testimony painted a chilling picture of planning, coercion, and control — revealing just how far one person was willing to go to keep a partner from leaving. We explore the forensic evidence that helped build the case, including tool mark comparisons, and discuss the strengths and limitations of these techniques in the broader context of modern forensic science. We also walk through the critical moments that prevented additional bombs from being delivered, highlighting how coordination between investigators and rapid communication helped stop further attacks before they could occur. This case is a stark reminder of how domestic violence can escalate and how manipulation and coercive control can lead to extreme violence. Buy Burn Boston Burn by Wayne M. Miller: https://a.co/d/ipCuGL2 Buy Bang Boom Burn by Wayne M. Miller: https://a.co/d/a2EACYf The Crime to Burn Patreon - The Cult of Steve - is LIVE NOW! Go join and get all the unhinged you can handle. Click here to be sanctified. Inner Sanctum Acknowledgments: Eternal gratitude to our Inner Sanctum patrons, Melanie Curtis, Jenny Mercer and Laura Pisciotta, for helping us bring light to the stories others would rather leave in the ashes. Listener discretion is advised. Background music by Not Notoriously Coordinated Get your Crime to Burn Merch! https://crimetoburn.myspreadshop.com Please follow us on Instagram, X, Facebook, TikTok and Youtube for the latest news on this case. You can email us at crimetoburn@gmail.com We welcome any constructive feedback and would greatly appreciate a 5 star rating and review. If you need a way to keep your canine contained, you can also support the show by purchasing a Pawious wireless dog fence using our affiliate link and use the code "crimetoburn" at checkout to receive 10% off. Pawious, because our dog Winston needed a radius, not a rap sheet. Miller, Wayne M. Bang Boom Burn: Explosive True Crime Gun, Bombing, and Arson Cases from a Federal Agent's Career. AuthorHouse, 2021. ISBN 978-1-7333403-5-9. Craig, Gary. “Christmas package bomber who killed 5 in New York dies in prison.” Rochester Democrat and Chronicle. Updated Nov. 14, 2024. “His mouth got him in trouble.” Associated Press, published in The Roanoke Times, Dec. 31, 1993 (Virginia Tech newspaper archive). United States of America v. Michael T. Stevens, 83 F.3d 60 (2d Cir. 1996). Justia. Van Biema, David. “Death on Delivery.” TIME. Jan. 10, 1994. “A Conviction in Case of 5 Deaths by Bombs.” The New York Times. Apr. 1, 1995. (Accessed via Murderpedia; direct link not captured.) “Jury Is Seated in Upstate Mail Bombing.” The New York Times. Mar. 7, 1995. (Accessed via Murderpedia; direct link not captured.) Van Gelder, Lawrence. “Plea Bargain in Mail Bombings That Killed 5 Upstate.” The New York Times. Feb. 9, 1995. (Accessed via Murderpedia; direct link not captured.) “How Detectives Caught the New York Serial Bomber.” Real Responders (YouTube). Posted Feb. 24, 2020. “N.Y. bombing plot may have taken shape as long as year ago.” Tampa Bay Times. Published Jan. 2, 1994; updated Oct. 6, 2005.
On this episode of Special Cloth Talk, the SCT brothers do an unconventional episode with no topic, just casual conversation. Hope you all enjoy.
Miot, et al. v. Trump, et al., No. 25-cv-02471 (D.D.C. Feb. 2, 2026)TPS for Haiti; pretextual termination of TPS; INA § 242(f); APA vacatur and set aside; APA stay; equal protection; McNary; using public statements in litigation Matter of G-M-I-, 29 I&N Dec. 431 (BIA 2026)reliability and persuasiveness of expert testimony; factual basis for expert opinion; CAT; imprisonment for drugs; China Matter of Yadav, 29 I&N Dec. 438 (BIA 2026)sua sponte reopening based on marriage to a U.S. citizen; equities acquired after removal order Michelin, et al. v. Warden Moshannon Valley Correctional Center, et al., No. 24-2990 (3d Cir. Feb. 2, 2026)EAJA; habeas; sovereign immunity canon; civil action; importance of habeas; unreasonable prolonged detention Montejo-Gonzalez, et al. v. Bondi, No. 21-304 (9th Cir. Feb. 5, 2026) (en banc)in absentia motion to reopen based on exceptional circumstances; unconscionable result; totality of the circumstances; traffic accidents; motivation to attend hearing Pinilla Perez v. Bondi, No. 23-6363 (2d Cir. Feb. 5, 2026)equitable tolling; reopening; OIL admission that N.Y. Penal Law § 220.39(1) attempted sale of cocaine is not a removable offense; Minter; N.Y. Crim. Proc. § 440.10(1)(k); change of law; reasonable diligence of removed noncitizensKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!The Pen and SwordClick me!Discount code: ImmigrationReview26 Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
Welcome to Astronomy Daily! Today we explore the new lunar space race as SpaceX shifts focus from Mars to the Moon, Europe establishes its Moonport company, and NASA continues Artemis II preparations. Plus, scientists solve the mystery behind auroras, explain Uranus's radiation anomaly from 1986, and SpaceX returns to flight after a brief stand-down.Join hosts Anna and Avery for your daily dose of space and astronomy news!---### Featured Stories**[00:00] Introduction**Your hosts Anna and Avery preview today's Moon-focused episode**[01:15] SpaceX Pivots from Mars to Moon**- Elon Musk announces strategic shift to lunar settlement- Moon city achievable in under 10 years vs 20+ for Mars- Launch windows: Moon every 10 days vs Mars every 26 months- Alignment with Trump's space policy and Artemis program- Mars plans delayed but not abandoned (5-7 year timeline)- History of Musk's changing Mars predictions**[05:30] Europe's Moonport Ambitions**- German aerospace company OHB establishes European Moonport Company- Consolidating lunar mission activities and future infrastructure- Involvement in ESA's Argonaut lander and Gateway ESPRIT module- Moon base concept developed with Munich Airport International- European funding commitments at ESA Ministerial Council- Italy leads Moon exploration funding at €284 million**[09:45] NASA Artemis II Progress Report**- Technicians replace seals after hydrogen leak detection- Tail service mast umbilical repairs and testing- Operational changes for next wet dress rehearsal- Extended countdown hold times for troubleshooting- Crew training continues: Wiseman, Glover, Koch, Hansen- March launch window still under consideration**[13:00] Aurora Power Source Discovered**- International team solves decades-old mystery- Alfvén waves act as natural particle accelerators- Analysis of Van Allen Probes and THEMIS mission data- Universal model applicable to other planets- Collaboration between HKU and UCLA researchers- Applications for Jupiter, Saturn, and exoplanet studies**[15:30] Uranus Radiation Mystery Solved**- Voyager 2's 1986 anomaly explained after 40 years- Co-rotating interaction region (CIR) supercharged radiation belts- Comparative analysis with Earth's space weather events- Southwest Research Institute breakthrough- Implications for future Uranus orbiter missions- Similar applications for Neptune studies**[18:00] SpaceX Falcon 9 Returns to Flight**- Successful Starlink launch from Vandenberg after 5-day stand-down- 25 satellites deployed to orbit (Group 17-33)- Booster 1088 completes 13th flight with successful landing- February 2nd upper stage anomaly explained- Gas bubble prevented deorbit burn- FAA clearance after corrective actions implemented- Starlink constellation exceeds 9,600 active satellites- SpaceX's 15th launch of 2026Become a supporter of this podcast: https://www.spreaker.com/podcast/astronomy-daily-space-news-updates--5648921/support.Sponsor Details:Ensure your online privacy by using NordVPN. To get our special listener deal and save a lot of money, visit www.bitesz.com/nordvpn. You'll be glad you did!Become a supporter of Astronomy Daily by joining our Supporters Club. Commercial free episodes daily are only a click way... Click HereThis episode includes AI-generated content.
Matter of E-A-S-O-, 29 I&N Dec. 422 (BIA 2026)particularly serious crime; N-A-M-; no misdemeanor presumption; Matter of Juarez; D.C. Code § 22-3010.01 sexual abuse of a minor; discretion; weighing hardship in discretionary analysis Matter of Laurent Castro, 29 I&N Dec. 419 (BIA 2026)in absentia; interlocutory appeal; “shall”; notice Bonilla-Espinoza v. Bondi, No. 24-9566 (10th Cir. Jan. 27, 2026)nexus; imputed gang member; exhaustion; due process; IJ failure to develop the record; translation issues; State of Exception; El Salvador Banyee v. Bondi, No. 24-3590 (8th Cir. Jan. 29, 2026)attempted theft; INA § 101(A)(43)(G)/(U); robbery in violation of North Dakota Century Code § 12.1-22-01; categorical approach; realistic probability test; unambiguous statute; lesser included offenseKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!The Pen and SwordClick me!Discount code: ImmigrationReview26 Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
On this episode the Special Cloth brothers discuss Andrew Schultz recent apology for his endorsement of Trump for the 2024 election. We also discuss Nicki Minaj's recent controversial decisions, release of more Epstein files, and more
Episode 99 Some crimes are impulsive. This one wasn't. In December 1993, six bombs were delivered across upstate New York in less than ninety minutes. Five people were killed. One survived by pure chance. Another device failed to detonate. And one bomb was unknowingly driven around the region in the back of a courier van before police could stop it. The victims weren't politicians. They weren't business rivals. They weren't part of an organized crime war. They were a family. In this episode, we begin breaking down Domestic Detonation—a coordinated bombing campaign driven not by ideology or profit, but by control. According to investigators, the targets shared one connection: they were the support system of a woman trying to leave a volatile relationship. Part 1 focuses on the human story and the investigation: The victims and the nearly identical package bombs How investigators realized these attacks were connected Why one woman was spared while the rest of her family was targeted The early suspects—and why nothing was as simple as it first appeared The unsettling role of loyalty, manipulation, and obsession in escalating violence We'll also introduce the two men at the center of the case—and the red flags investigators couldn't ignore. In Part 2, we'll shift into the forensic evidence: How investigators linked the bombs What the explosive components revealed The confession—and the questions surrounding it How forensic reconstruction unraveled the plot piece by piece Buy Burn Boston Burn by Wayne M. Miller: https://a.co/d/ipCuGL2 Buy Bang Boom Burn by Wayne M. Miller: https://a.co/d/a2EACYf The Crime to Burn Patreon - The Cult of Steve - is LIVE NOW! Go join and get all the unhinged you can handle. Click here to be sanctified. Inner Sanctum Acknowledgments: Eternal gratitude to our Inner Sanctum patrons, Melanie Curtis, Jenny Mercer and Laura Pisciotta, for helping us bring light to the stories others would rather leave in the ashes. Listener discretion is advised. Background music by Not Notoriously Coordinated Get your Crime to Burn Merch! https://crimetoburn.myspreadshop.com Please follow us on Instagram, X, Facebook, TikTok and Youtube for the latest news on this case. You can email us at crimetoburn@gmail.com We welcome any constructive feedback and would greatly appreciate a 5 star rating and review. If you need a way to keep your canine contained, you can also support the show by purchasing a Pawious wireless dog fence using our affiliate link and use the code "crimetoburn" at checkout to receive 10% off. Pawious, because our dog Winston needed a radius, not a rap sheet. Miller, Wayne M. Bang Boom Burn: Explosive True Crime Gun, Bombing, and Arson Cases from a Federal Agent's Career. AuthorHouse, 2021. ISBN 978-1-7333403-5-9. Craig, Gary. “Christmas package bomber who killed 5 in New York dies in prison.” Rochester Democrat and Chronicle. Updated Nov. 14, 2024. “His mouth got him in trouble.” Associated Press, published in The Roanoke Times, Dec. 31, 1993 (Virginia Tech newspaper archive). United States of America v. Michael T. Stevens, 83 F.3d 60 (2d Cir. 1996). Justia. Van Biema, David. “Death on Delivery.” TIME. Jan. 10, 1994. “A Conviction in Case of 5 Deaths by Bombs.” The New York Times. Apr. 1, 1995. (Accessed via Murderpedia; direct link not captured.) “Jury Is Seated in Upstate Mail Bombing.” The New York Times. Mar. 7, 1995. (Accessed via Murderpedia; direct link not captured.) Van Gelder, Lawrence. “Plea Bargain in Mail Bombings That Killed 5 Upstate.” The New York Times. Feb. 9, 1995. (Accessed via Murderpedia; direct link not captured.) “How Detectives Caught the New York Serial Bomber.” Real Responders (YouTube). Posted Feb. 24, 2020. “N.Y. bombing plot may have taken shape as long as year ago.” Tampa Bay Times. Published Jan. 2, 1994; updated Oct. 6, 2005.
Friday, January 30th, 2026Today, Democrats in the Senate have blocked the government funding package over ICE/CBP; Pam Bondi has appointed a special attorney to oversee Trump's probe into fake 2020 election fraud claims; the Justice Department has filed federal charges against the man who attacked Ilhan Omar; a former deputy has been sentenced to 20 years in prison for the murder of Sonya Massey; the 9th Circuit says DHS illegally ended the Venezuelan Temporary Protected Status program; and the Federal Reserve says it won't cut interest rates this month; and Allison and Dana deliver your Good News.Guest: John FugelsangTell Me Everything|John Fugelsang, The John Fugelsang Podcast, John Fugelsang|Substack, @johnfugelsang|Bluesky, @JohnFugelsang|TwitterSeparation of Church and Hate by John Fugelsang - OUT NOW! Dana Goldberg Tour Dates The LatestIs Now the Time to Demand a Clawback of the ICE BBB Slush Fund?StoriesUPDATED:Democrats Reach Spending Deal With Trump, Seeking to Rein in ICE - The New York TimesDHS Illegally Ended Venezuelan Migrant Status, 9th Cir. Says (1) | Bloomberg LawBondi Hands St. Louis Prosecutor Nationwide Election Fraud Remit | Bloomberg LawFormer Illinois sheriff's deputy sentenced to 20 years for murder of Sonya Massey | NBC News Good TroubleGood Trouble for today is: if you can, participate in the General Strike by not participating in the economy on Friday.→Standwithminnesota.com→Tell Congress Ice out Now | Indivisible→Defund ICE (UPDATED 1/21) - HOUSE VOTE THURSDAY→Congress: Divest From ICE and CBP | ACLU→ICE List →iceout.org→standwithminnesota.com →2026 Trans Girl Scouts To Order Cookies From! | Erin in the Morning Good NewsHanover Board asks ICE to reconsider proposed facilityDog Adoptable - Kurt a Hound Dog in Ashland, VA | PetfinderHeather Cox RichardsonDaddysCoffeeandSweets|YouTubeKaren Refugee Wrongly Detained by ICE in Minnesota Released | Burma InsightTour — DANA GOLDBERG→Go To Good News & Good Trouble - The Daily Beans to Share YoursSubscribe to the MSW YouTube Channel - MSW Media - YouTubeOur Donation LinksPathways to Citizenship link to MATCH Allison's Donationhttps://crm.bloomerang.co/HostedDonation?ApiKey=pub_86ff5236-dd26-11ec-b5ee-066e3d38bc77&WidgetId=6388736Allison is donating $20K to It Gets Better and inviting you to help match her donations. Your support makes this work possible, Daily Beans fam. Donate to It Gets Better / The Daily Beans FundraiserJoin Dana and The Daily Beans with a MATCHED Donation http://onecau.se/_ekes71More Donation LinksNational Security Counselors - Donate
Guevara-Serrano, et al. v. Bondi, No. 23-4420 (9th Cir. Jan. 20, 2026) unable or unwilling to protect; no police reporting requirement; Burbano; uncontradicted testimony; domestic violence; gangs; Honduras Matter of S-M-H-, 29 I&N Dec. 412 (BIA 2026) frivolous asylum filing warning; dual citizenship; materiality; written warnings United States v. Singer, No. 23-6120 (10th Cir. Jan. 23, 2026) crime of violence; unborn persons; fetus; statutory interpretation; legislative silence; assault and battery with a dangerous weapon in violation of Okla. Stat. tit. 21, § 645 Fortes Tomar v. Bondi, No. 24-2108 (1st Cir. Jan. 23, 2026) CIMT; lewd; sexual intent; Mass. Gen. L., ch. 272, § 16; unpublished state case to satisfy realistic probability test; PFR grant without remand Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!The Pen and SwordClick me! Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
Hypertrophic Cardiomyopathy (HCM) is the most common genetic heart disease in the US. Guest James Norton, BSN, RN, shares the hallmark signs and symptoms, and describes how shared decision-making in the care of patients with HCM from diverse populations.Related resources:AHA HCM sudden cardiac death risk calculator: https://professional.heart.org/en/guidelines-and-statements/hcm-risk-calculatorClinical Course & Management of HCM: https://www.nejm.org/doi/full/10.1056/NEJMra1710575HCM Sudden Cardiac Death Calculator: https://professional.heart.org/en/guidelines-and-statements/hcm-risk-calculator2024 AHA/ACC Guideline for the Management of HCM: https://www.ahajournals.org/doi/10.1161/CIR.0000000000001250See Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.
Cardiologist Bob Harrington talks to Mitch Elkind, chief science officer for Brain Health and Stroke at the AHA, about the heart-brain connection and why what's good for the brain is good for the heart. This podcast is intended for healthcare professionals only. To read a transcript or to comment, visit https://www.medscape.com/author/bob-harrington Life's Essential 8: Updating and Enhancing the American Heart Association's Construct of Cardiovascular Health: A Presidential Advisory From the American Heart Association https://www.ahajournals.org/doi/10.1161/CIR.0000000000001078 Migraine Headache: An Under-Appreciated Risk Factor for Cardiovascular Disease in Women https://www.ahajournals.org/doi/10.1161/JAHA.119.014546 Cardiovascular disease patients have increased risk for comorbidity: A cross-sectional study in the Netherlands https://doi.org/10.1080/13814788.2017.1398318 Characteristics and treatment of midlife-onset epilepsy: A 24-year single-center, retrospective study https://doi.org/10.1002/epd2.20253 Traumatic Brain Injury and Risk of Neurodegenerative Disorder https://doi.org/10.1016/j.biopsych.2021.05.025 Cardiac Changes in Parkinson's Disease: Lessons from Clinical and Experimental Evidence https://doi.org/10.3390/ijms222413488 The neuropathological diagnosis of Alzheimer's disease https://doi.org/10.1186/s13024-019-0333-5 Failed Semaglutide for Early Alzheimer's Not the End of the Road? https://www.medscape.com/viewarticle/failed-semaglutide-early-alzheimers-not-end-road-2025a1000y4l Atrial Fibrillation and Dementia: A Report From the AF-SCREEN International Collaboration https://doi.org/10.1161/circulationaha.121.055018 Reduced regional cerebral blood flow in patients with heart failure https://doi.org/10.1002/ejhf.874 Heart-brain Interactions in Heart Failure https://doi.org/10.15420/cfr.2018.14.2 While You Were Sleeping, the Brain's 'Waste Disposal System' Was at Work https://www.medscape.com/viewarticle/while-you-were-sleeping-brains-waste-disposal-system-was-2025a1000mbb Repurposing Semaglutide and Liraglutide for Alcohol Use Disorder https://doi.org/10.1001/jamapsychiatry.2024.3599 2025 AHA/ACC/AANP/AAPA/ABC/ACCP/ACPM/AGS/AMA/ASPC/NMA/PCNA/SGIM Guideline for the Prevention, Detection, Evaluation and Management of High Blood Pressure in Adults: A Report of the American College of Cardiology/American Heart Association Joint Committee on Clinical Practice Guidelines https://www.ahajournals.org/doi/10.1161/CIR.0000000000001356 "VOODOO" Death https://ajph.aphapublications.org/doi/full/10.2105/AJPH.92.10.1593 Longitudinal brain ageing after stroke: a marker for neurodegeneration and its relevance for upper limb motor outcome https://doi.org/10.1093/braincomms/fcaf299 Unlocking Longevity: Aging Reimagined https://www.medscape.com/viewarticle/1002241 You may also like: Hear John Mandrola, MD's summary and perspective on the top cardiology news each week, on This Week in Cardiology https://www.medscape.com/twic Questions or feedback, please contact news@medscape.net
United States v. Ramiro Gomez, No. 23-435 (9th Cir. Jan. 13, 2026) (en banc) crime of violence; recklessness; Borden; Cal. Pen. Code § 245(a)(1) assault with a deadly weapon other than a firearm; intent, knowing; mens rea; Federal Rule of Criminal Procedure 52; plain error Matter of D-G-B-L-, 29 I&N Dec. 392 (BIA 2026) serious non political crime; drug trafficking activity; duress; statutory interpretation; Neguise; CAT; Sinaloa cartel; domestic violence; acquiesce; insufficient police reporting Matter of Laparra-Deleon, 29 I&N Dec. 389 (BIA 2026) deficient NTA; in absentia motions to reopen; Campos Chavez Matter of M-C-C-, 29 I&N Dec. 401 (BIA 2026) INA § 237(a)(1)(H) waiver; fraud or willful misrepresentation; INA § 212(a)(6)(C)(i); military service during Bosnian War; discretion; history of untruthfulness; adverse inference from invoking Fifth Amendment; family ties must outweigh fraud Mukantagara, et al. v. Noem, et al., No. 24-4071 (10th Cir. Jan. 12, 2026) discretion; INA § 242(a)(2)(B)(ii); INA § 207(c)(4); termination of asylum status; Rwanda genocide Fuentes-Pineda v. Bondi, No. 24-60592 (5th Cir. Jan. 14, 2026) and Sayegh de Kewayfati, et al. v. Bondi, et al., No. 25-20073 (5th Cir. Jan 14, 2025) prison conditions; state of exception; former gang members; past torture; Amnesty International reports; El Salvador jurisdiction for APA lawsuit over denial of affirmative asylum application; TPS Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!The Pen and SwordClick me! Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewCase notesSupport the show
Wolford v. Lopez | 01/20/26 | Docket #: 24-1046 24-1046 WOLFORD V. LOPEZ DECISION BELOW: 116 F.4th 959 LIMITED TO QUESTION 1 PRESENTED BY THE PETITION. CERT. GRANTED 10/3/2025 QUESTION PRESENTED: New York State Rifle & Pistol Association, Inc. v. Bruen , 597 U.S. 1, 33 (2022), holds that "the Second Amendment guarantees a general right to public carry" of arms, meaning ordinary, law-abiding citizens may "'bear' arms in public for self-defense." In this case, the Ninth Circuit sustained a Hawaii law that makes it a crime for a concealed carry permit holder to carry a handgun on private property unless he has been "given express authorization to carry a firearm on the property by the owner, lessee, operator, or manager of the property." H.R.S. § 134-9.5. That holding is in acknowledged direct conflict with the Second Circuit's holding in Antonyuk v. James , 120 F.4th 941 (2d Cir. 2024), a decision that struck down an identical State law in the same procedural posture as this case. The Ninth Circuit also sustained a multitude of other location bans on carry by permit holders, relying solely on post-Reconstruction Era and later laws. That doctrinal approach is in direct conflict with the Third Circuit's decision in Lara v. Commissioner Pennsylvania State Police , 125 F.4th 428 (3d Cir. 2025), the Fifth Circuit's decision in United States v. Connelly , 117 F.4th 269 (5th Cir. 2024), the Eighth Circuit's decision in Worth v. Jacobson , 108 F.4th 677 (8th Cir. 2024), and, most recently, the Eleventh Circuit's en banc decision in NRA v. Bondi , No. 21- 12314, 2025 WL 815734 at *5 (11th Cir. March 14,2025) (en banc), all of which hold that primary focus must be on Founding generation laws and tradition in applying the text, history and tradition test Bruen mandates. The questions presented are: 1. Whether the Ninth Circuit erred in holding, in direct conflict with the Second Circuit, that Hawaii may presumptively prohibit the carry of handguns by licensed concealed carry permit holders on private property open to the public unless the property owner affirmatively gives express permission to the handgun carrier? 2. Whether the Ninth Circuit erred in solely relying on post-Reconstruction Era and later laws in applying Bruen 's text, history and tradition test in direct conflict with the holdings of the Third, Fifth, Eighth and Eleventh Circuits? LOWER COURT CASE NUMBER: 23-16164
VLOG Jan 20 Epstein victim files SDNY, Mangione 9 Cir for Jan 23 (Alexander bros unseal Jan 23, openings Jan 26). MLK Day CRA challenges by Fair Finance Watch in Alabama & Arkansas, UNMIK corruption
The Taproot Therapy Podcast - https://www.GetTherapyBirmingham.com
Can Therapists Start a Union? The Antitrust Trap, the Shadow Committee, and the Economic Strangulation of American Psychotherapy Analyzing America's Healthcare Regulations and Their Effect on Us: Why the Law Prevents Therapists from Organizing While Allowing a Private Committee to Fix Prices for the Entire Medical System https://gettherapybirmingham.com/can-therapists-start-a-union-spoiler-alert-they-cant/ The Monthly Rage Thread If you hang around therapist forums long enough, you will see it happen. It operates with the regularity of the tides. Someone posts a thread, usually after receiving a contract from an insurance company offering 1998 rates for 2025 work, and asks the obvious question: “We are the ones providing the care. The system collapses without us. Why don't we just all go on strike? Why don't we form a union and demand fair pay?” It is a logical question. In almost every other sector of the economy, workers who feel exploited band together to negotiate better terms. Screenwriters shut down Hollywood to get paid for streaming residuals. Auto workers walk off the line. Teachers fill the state capitol. Nurses at major hospital systems have successfully unionized and won significant concessions. So why, in the midst of a national mental health crisis, does the mental health workforce remain so politically impotent? The answer is not that we lack will. It is not that we lack organization. The answer is that for private practice therapists, forming a union is a federal crime. This is not a political manifesto. It is an analysis of the bizarre regulatory environment that governs American healthcare, a system of antitrust laws, shadow committees, and bureaucratic classifications that effectively strips clinicians of their bargaining power while empowering the corporations that pay them. If you want to understand why corporate tech monopolies are ruining therapy, or why the corporatization of healthcare feels so suffocating, you have to understand the legal straitjacket we are all wearing. And you have to understand the one group that is allowed to set prices, the one group exempt from the rules that bind the rest of us. Part I: You Are Not a Worker, You Are a Standard Oil Tycoon The primary reason therapists cannot unionize dates back to the era of oil barons and railroad tycoons. The Sherman Antitrust Act of 1890 was designed to prevent massive corporations like Standard Oil from colluding to fix prices and destroy the free market. It prohibits “every contract, combination… or conspiracy, in restraint of trade.” The law was a response to genuine abuses: companies buying up competitors, dividing territories, and coordinating prices to gouge consumers who had no alternatives. Here is the catch: In the eyes of the federal government, a private practice therapist is not a “worker.” You are a business entity. Even if you are a solo practitioner struggling to pay rent in a subleased office, seeing clients between crying in your car and eating lunch at your desk, the law views you as the CEO of a micro-corporation. You are classified as a 1099 independent contractor, not a W-2 employee, and that distinction makes all the difference in the world. If two workers at Starbucks talk about their wages and agree to ask for a raise, that is “collective bargaining,” which is protected by the National Labor Relations Act. But if two private practice therapists talk about their reimbursement rates and agree to ask Blue Cross for a raise, that is “price-fixing.” It is legally indistinguishable, in the eyes of the Federal Trade Commission, from gas stations conspiring to raise the price of unleaded. It sounds absurd, but the FTC takes it deadly seriously. When independent contractors organize to demand higher rates, when they share information about what they are being paid and coordinate their responses, they are engaging in horizontal price-fixing, one of the most serious violations of antitrust law. The Sherman Act provides for criminal penalties, including fines and imprisonment. The law that was meant to break up monopolies is now used to prevent social workers from asking for a cost-of-living adjustment. The irony is crushing. The same regulatory framework that prevents two therapists from discussing their rates allows massive insurance conglomerates to merge repeatedly, concentrating buyer power in fewer and fewer hands. UnitedHealth Group, for example, has acquired dozens of companies over the past two decades, becoming the largest healthcare company in the United States. When they offer a “take it or leave it” contract to providers, they do so with the full knowledge that fragmented, legally prohibited from organizing therapists have no counter-leverage. The antitrust laws, designed to prevent monopoly power, have created a system where sellers are atomized and buyers are consolidated. Economists call this “monopsony,” and it is precisely the market distortion the Sherman Act was supposed to prevent. Part II: The Day the “Learned Profession” Died For a long time, doctors and lawyers thought they were exempt from these laws. They argued that they were “learned professions,” not mere tradespeople, and therefore above the grubby laws of commerce. They believed that their ethical obligations to patients and clients set them apart from the rules that governed steel mills and meatpacking plants. Medicine was a calling, not a business, and surely the government would not regulate the sacred doctor-patient relationship as if it were a commercial transaction. That illusion was shattered in 1975 by the Supreme Court case Goldfarb v. Virginia State Bar. The case involved lawyers, not doctors, but its implications cascaded through every licensed profession in America. The Goldfarbs were purchasing a home and needed a title examination. The Virginia State Bar had established a minimum fee schedule for such services, and every lawyer they contacted quoted the exact same price. They sued, arguing that this fee schedule was illegal price-fixing. The Supreme Court agreed. In a unanimous decision, the Court ruled that professional services, including legal and medical advice, are “trade or commerce” subject to antitrust laws. The “learned profession” exemption, which had been assumed but never explicitly established in law, was declared a myth. “The nature of an occupation, standing alone,” the Court wrote, “does not provide sanctuary from the Sherman Act.” This ruling was intended to lower prices for consumers by preventing lawyers from setting minimum fees, and in that narrow sense it was a good thing. But in healthcare, it had a catastrophic side effect: it made it illegal for doctors and therapists to band together to resist the pricing power of insurance companies. The “learned profession” exemption is dead. We are now just businesses, and businesses are not allowed to hold hands. This creates the illusion of progress: we have “free market” competition among providers, but monopsony power among payers. It is a market where the sellers are forbidden from organizing, but the buyers are allowed to merge until they are too big to fail. The result is not a free market at all. It is a market designed to transfer wealth from one class (providers) to another (insurers and administrators), with the law itself serving as the enforcement mechanism. Part III: The Cartel in the Basement If therapists cannot collude to set prices, surely nobody else can, right? Wrong. There is one group in American healthcare that is allowed to meet in a room, decide what every doctor's time is worth, and set prices for the entire industry. It is called the RUC, the AMA/Specialty Society Relative Value Scale Update Committee. And understanding the RUC is the key to understanding why talk therapy is dying in the medical model, why psychiatrists abandoned the couch for the prescription pad, and why your insurance company offers you a ghost network of providers who never answer the phone. The Birth of a Shadow Government To comprehend the current crisis in mental health economics, one must excavate the foundations of the physician payment system. Prior to 1992, Medicare reimbursed physicians based on a system known as “Customary, Prevailing, and Reasonable” charges. Under this system, physicians were paid based on their historical billing charges. It was inherently inflationary; it rewarded those who raised their fees most aggressively and created wide geographic disparities for identical services. In response to spiraling costs, Congress passed the Omnibus Budget Reconciliation Act of 1989, mandating a transition to a fee schedule based on the resources required to provide a service. This birthed the Resource-Based Relative Value Scale. The intellectual architecture for this system was developed by a team of economists at Harvard University, led by William Hsiao. Hsiao's team sought to create a “unified theory” of medical value, attempting to quantify the “work” involved in disparate medical acts, comparing the cognitive intensity of a psychiatric evaluation with the technical skill of a hernia repair. The Harvard study was revolutionary. It promised to level the playing field, suggesting that cognitive services, the thinking and talking that comprises primary care and mental health, were vastly undervalued relative to surgical procedures. Had Hsiao's original recommendations been implemented purely, the income gap between generalists and specialists might have narrowed significantly. But the administrative complexity of assigning values to over 7,000 Current Procedural Terminology codes overwhelmed the Health Care Financing Administration. Into this administrative vacuum stepped the American Medical Association. The AMA, fearing that the government would unilaterally set prices, proposed a “partnership.” They would convene a committee of experts to maintain and update the relative values, providing this labor-intensive service to the government at no cost. The government accepted. Thus, in 1991, the RUC was born, not as a government agency, but as a private advisory body with unparalleled influence over public funds. The Architecture of Control The RUC's claim to legitimacy rests on its status as an “expert panel.” But a structural analysis of its composition reveals a profound bias that mimics the governance of a cartel designed to protect incumbent interests. The committee consists of 32 members, but power is concentrated in the 29 voting seats. Of these, 21 seats are appointed by major national medical specialty societies. The distribution is not proportional to the volume of services provided to Medicare beneficiaries, nor is it proportional to the physician workforce. Instead, it is frozen in a historical moment that favored high-technology specialties. Primary care physicians, who perform roughly 45 to 50 percent of Medicare work, hold approximately 4 to 5 seats, giving them about 17 percent of the vote. Procedural and surgical specialties, including surgery, radiology, and anesthesiology, hold 15 to 18 seats, giving them roughly 60 percent of the vote despite performing only 35 to 40 percent of Medicare work. The American Psychiatric Association holds a single seat. One seat. This lone representative must negotiate with a supermajority of specialists, neurosurgeons, cardiothoracic surgeons, radiologists, and ophthalmologists, whose financial interests are often diametrically opposed to the valuation of cognitive work. The cartel dynamic is enforced by a statutory requirement of budget neutrality. The Medicare Physician Fee Schedule is a zero-sum game. If the total relative value units projected for a given year exceed the budget, a “scaler” is applied to reduce the conversion factor, effectively cutting everyone's pay. Therefore, any proposal to increase the value of psychotherapy, which would increase the total RVU spend, effectively asks every surgeon in the room to take a pay cut to fund the raise for psychiatrists. Given that a two-thirds majority is required to pass a recommendation, the procedural bloc holds absolute veto power over any redistribution of wealth. The Secret Chamber A hallmark of cartel behavior is the restriction of information. For nearly two decades, the RUC operated in near-total secrecy. While recent years have seen minor concessions to transparency, such as the publication of vote totals, the core deliberative process remains opaque. RUC meetings are private. The public, the press, and even non-RUC physicians are largely barred from attending the deliberations where billions of tax dollars are allocated. Participants, including the specialty advisors who present data, must sign strict non-disclosure agreements. These agreements prevent them from discussing the specific tradeoffs, deals, or arguments made within the chamber. A former RUC participant described these agreements as “draconian,” designed to insulate the committee from public accountability. The Government Accountability Office and the Center for American Progress have noted the inherent conflict of interest. The individuals setting the prices are the same individuals who receive the payments. Unlike a regulatory agency, where officials are salaried and divested of industry assets, RUC members are practicing physicians whose personal incomes are directly tied to the decisions they make. This secrecy serves a functional purpose: it allows for “logrolling.” A representative from Orthopedics might support an inflated value for a Cardiology code in exchange for Cardiology's support on a Knee Replacement code. This “I'll scratch your back” dynamic creates an upward pressure on procedural values that excludes those outside the dominant coalition, specifically primary care and mental health. The Antitrust Shield Why has the Department of Justice not broken up this cartel? The legal shield is the Noerr-Pennington Doctrine. This Supreme Court doctrine establishes that private entities are immune from antitrust liability when they are petitioning the government. Because the RUC technically only “recommends” values to CMS (that is petitioning), and CMS “decides” (that is government action), the RUC is protected by the First Amendment right to petition. This legal loophole allows the RUC to operate with monopolistic characteristics without fear of prosecution, provided CMS continues to go through the motions of “reviewing” the recommendations. And CMS accepts those recommendations over 90 percent of the time. Because private insurance companies generally base their rates on Medicare, this private committee effectively sets the price of healthcare for the entire country. If independent therapists did this, if they gathered in a room and agreed on what their services should cost, they would face criminal prosecution. But because the RUC operates under the fiction of “advising” the government, it is protected. The same regulatory framework that criminalizes therapist solidarity provides cover for industry-wide price coordination by the most powerful medical specialties. Part IV: The Mechanics of Suppression To control a market, one must control its currency. In American medicine, that currency is the Relative Value Unit. Every medical service, from a 15-minute therapy session to a heart transplant, is assigned a total RVU value. This value is the sum of three components: the Work RVU, which accounts for physician time, technical skill, mental effort, and judgment; the Practice Expense RVU, which covers overhead costs like rent, staff, and equipment; and the Malpractice RVU, which reflects professional liability insurance costs. The Work RVU, which comprises roughly 50 to 55 percent of the total value, is determined by RUC surveys. When a code is flagged for review, the relevant specialty society distributes a survey to a sample of its members. These respondents are asked to estimate the time and intensity of the service compared to a “reference service.” This methodology violates several principles of statistical validity. The surveys are voluntary and distributed by the specialty societies themselves. The respondents are typically those most active in the society and most invested in maximizing reimbursement, advocates rather than neutral observers. The sample sizes are often shockingly small; RUC surveys frequently rely on fewer than 50 or 70 respondents to set the price for services performed millions of times annually. A sample of 30 orthopedic surgeons might determine the value of a procedure costing Medicare billions. The Time Arbitrage The most critical variable in the RUC equation is time. The Work RVU is conceptually derived from the formula: Work equals Time multiplied by Intensity. Therefore, inflating the time estimate is the most direct route to inflating the price. Independent studies by RAND and the Urban Institute, often using objective data like Operating Room logs, have consistently shown that the RUC overestimates the time required for surgical procedures. A procedure valued by the RUC as taking 60 minutes may, in reality, take 30 minutes. This creates an arbitrage opportunity. If a gastroenterologist can perform a “60-minute” colonoscopy in 20 minutes, they can effectively perform three procedures in the time allotted for one. They bill for three hours of work in one hour of real time. This “efficiency gain” is captured entirely by the physician as profit. Psychotherapy cannot utilize this arbitrage. CPT codes for psychotherapy are explicitly time-based in their definition. Code 90832 requires 16 to 37 minutes. Code 90834 requires 38 to 52 minutes. Code 90837 requires 53 minutes or more. A psychiatrist cannot perform a 60-minute therapy session in 20 minutes; doing so constitutes fraud. Therefore, the revenue of a psychotherapist is capped by the linear passage of time. They can sell, at maximum, roughly 8 to 10 units of labor per day. A proceduralist, aided by RUC-inflated time assumptions, can sell 20 or 30 units of “RUC time” in the same day. This structural discrepancy creates a widening income gap that no amount of “hard work” by the therapist can close. It is not a market failure. It is market design. The “Thinking” Penalty The RUC's bias is not merely structural; it is philosophical. The committee, dominated by surgeons and proceduralists, consistently values “doing things to people,” cutting, scanning, injecting, far more highly than “talking to people,” diagnosing, counseling, managing complex chronic conditions. This creates a regulatory environment that functions as a de facto wealth transfer from cognitive care to procedural care. In 2013, a major revision of psychiatry codes exposed this bias in stark relief. Previously, psychiatrists used codes that bundled the medical evaluation with the psychotherapy. The new system required psychiatrists to bill an E/M code for the medical management plus an “add-on” code for psychotherapy. While intended to improve transparency, this change exposed psychotherapy to the raw mechanics of the RUC's valuation bias. By isolating the “therapy” component, the committee could subject it to rigorous cross-specialty comparison. And the committee, dominated by surgeons, views “talking to a patient” as low-intensity work compared to “operating on a patient.” The economic signal was clear. This created the 15-minute med check culture not because psychiatrists stopped caring, but because the regulatory environment made relational care financial suicide. It effectively “illegalized” the practice of deep, slow psychiatry for anyone who wanted to take insurance. Part V: The “Messenger Model” and Other Legal Fictions When therapists ask about collective bargaining, lawyers will often point them to the only legal loophole available: the “Messenger Model.” In this model, a third party (the messenger) acts as an intermediary between a group of providers and an insurance company. The messenger takes the insurance company's offer and conveys it to each therapist individually. Each therapist must then make a unilateral, independent decision to accept or reject it. The messenger is strictly forbidden from negotiating. They cannot say, “The group rejects this.” They cannot say, “We want 10% more.” They cannot advise the therapists on what to do. They can only carry messages. This is why “Independent Practice Associations” are often toothless. In the 2008 case North Texas Specialty Physicians v. FTC, the Fifth Circuit Court of Appeals made clear that if an IPA actually tries to leverage its numbers to demand better rates, it violates antitrust laws. If it follows the messenger model, it has no leverage. It is a “heads I win, tails you lose” regulatory structure designed to protect payers, not providers. The only exception is “clinical integration,” where providers genuinely merge their practices, share infrastructure, and accept joint financial risk. But this requires substantial capital investment and essentially means ceasing to be an independent practitioner. It is a legal pathway available mainly to large physician groups and hospital systems, not to solo therapists working out of rented offices. Part VI: Market Distortions and the Flight to Cash When a cartel sets a price below the market equilibrium, suppliers exit the formal market. This is precisely what has happened in psychotherapy. Mental health providers generally have lower overhead than surgeons. They do not need MRI machines or sterile surgical suites. And they face high consumer demand; the national mental health crisis ensures a steady stream of people seeking services. This gives them an “exit option” that proceduralists do not have. They can refuse to accept insurance and operate as cash-only businesses. The statistics are stark. Nearly 50 percent of psychiatrists do not accept commercial insurance, compared to less than 10 percent of other specialists. A 2023 survey indicated that 64 percent of private practice therapists planned to increase their cash-pay rates. Research published in Health Affairs Scholar found that patients are 10.6 times more likely to go out-of-network for mental health care than for medical/surgical care. This mass exodus is a rational economic response to RUC-suppressed rates. If the RUC says an hour of therapy is worth $100 via the RVU-to-dollar conversion, but the market demand is willing to pay $250, the provider will leave the RUC-controlled sector. They are not abandoning their profession; they are abandoning a pricing regime that values their work at less than half its market rate. Ghost Networks The RUC's pricing failure creates “Ghost Networks,” directories filled with providers who are ostensibly “in-network” but are functionally inaccessible. They are either full, not accepting new patients, retired, have moved, or simply do not respond to inquiries from insurance-based patients because the administrative burden of prior authorizations and clawbacks outweighs the suppressed fee. This is not a “shortage” of providers in the absolute sense. There is no shortage of therapists in private practice. There is a shortage of therapists willing to work at the RUC-determined price point. The insurance directories are graveyards of phantom availability, creating the illusion of access where none exists. The Cost Paradox The central thesis of the RUC's defenders is that they “control costs.” By strictly managing RVUs, they claim to save taxpayer money. In psychotherapy, this logic backfires catastrophically. By suppressing reimbursement rates to a level that drives providers out of the network, the RUC forces patients into the cash market. The theoretical in-network cost might be a $20 copay with the insurer paying $100. The actual out-of-network cost is $250 cash out-of-pocket, paid in full by the patient. Thus, the “cost of therapy” for the consumer skyrockets. Therapy becomes a luxury good, accessible only to those with disposable income. For the poor and middle class, the “cost” is effectively infinite, because the service becomes inaccessible. The RUC's cost-control measure for the system becomes a cost-multiplier for the patient. It shifts the financial burden from the risk pool, where it belongs, to the individual, where it causes maximum harm. The Signal to Students The RUC sends powerful economic signals to medical students making career decisions. When a student observes that a dermatologist or radiologist can earn $500,000 working regular hours, while a psychiatrist earns $240,000 handling emotional trauma and on-call emergencies, while a primary care doctor earns even less, the choice is clear for those motivated by financial security. The undervaluation of cognitive codes discourages the best and brightest from entering mental health and primary care. The cartel's pricing structure creates a perpetual labor shortage in the fields most needed for public health, while creating a surplus in high-margin procedural specialties. We then wonder why there are not enough psychiatrists, why primary care is in crisis, why mental health access is collapsing. The answer is in the price signal, and the price signal is set by a committee of proceduralists meeting behind closed doors. The Hands Are Tied The question “Why can't therapists start a union?” is not just a labor question. It is a window into the broken soul of American healthcare. We have built a system where a secret committee of proceduralists can legally fix prices to favor surgery over therapy, but a group of social workers cannot band together to ask for a living wage. We have utilized laws meant to break up Standard Oil to break up the solidarity of caregivers. The same regulatory framework that criminalizes therapist coordination provides legal cover for industry-wide price coordination by the most powerful medical specialties. The result is a regulatory environment that drives doctors crazy, burns out therapists, and leaves patients navigating a fragmented, assembly-line system that was never designed to heal them. It was designed to process them. Until we confront the legal architecture of this system, the RUC, the Sherman Act, the 1099 trap, we will remain powerless to change it. And the reality of therapy is that quick fixes, whether in treatment or in policy, usually end up costing us more in the end. Some states are beginning to push back. New York and California have implemented strict network adequacy standards requiring mental health appointments within 10 business days. These regulations force insurers to expand their networks, which means they must attract providers, which means they must raise reimbursement rates above the RUC/Medicare floor. It is effectively a state-level override of the RUC cartel, forcing capital back into the mental health labor market. The Medicare Payment Advisory Commission has long advocated for stripping the RUC of its power, proposing the use of empirical data, tax returns, payroll records, practice invoices, to set values automatically. But these are patchwork solutions to a systemic problem. The fundamental issue remains: we have created a healthcare system that knows the price of everything and the value of nothing. We have engineered a system where the only way to survive is to stop acting like a healer and start acting like a factory. And we have wrapped this system in a legal framework that criminalizes resistance while protecting the status quo. The hands are tied. But at least now we can see the ropes. Bibliography For those interested in the primary sources and legal texts that underpin this analysis, the following external resources provide high-trust verification of the claims made above: Goldfarb v. Virginia State Bar, 421 U.S. 773 (1975): The Supreme Court decision that ended the “learned profession” exemption from antitrust laws. Read the Oyez Summary. The Sherman Antitrust Act (15 U.S.C. §§ 1–7): The foundational text of US antitrust law prohibiting restraint of trade. Read the Document at the National Archives. North Texas Specialty Physicians v. Federal Trade Commission (5th Cir. 2008): A key ruling establishing that independent physicians cannot collectively bargain on fees without financial integration. Read the Court Opinion. FTC/DOJ Statements of Antitrust Enforcement Policy in Health Care (1996): The federal guidelines explaining the “Messenger Model” and the narrow exceptions for clinical integration. Read the Guidelines (PDF). The RUC (AMA/Specialty Society RVS Update Committee): The AMA's own description of the committee structure and its role in valuing physician work. Visit the AMA RUC Page. “Special Deal” by Haley Sweetland Edwards (Washington Monthly, 2013): An investigative deep-dive into how the RUC operates and its impact on primary care vs. specialty pay. Read the Investigation. The National Labor Relations Act (NLRA): The law governing the right to unionize, which specifically excludes independent contractors. Read the NLRA. Laugesen, Miriam J. Fixing Medical Prices: How Physicians Are Paid. Harvard University Press, 2016. The definitive scholarly analysis of the RUC's history, structure, and influence on American healthcare pricing. Government Accountability Office. “Medicare Physician Payment Rates: Better Data and Greater Transparency Could Improve Accuracy.” 2015. GAO's critical analysis of RUC methodology and conflicts of interest. Center for American Progress. “Rethinking the RUC.” 2015. Policy analysis of the RUC's structural bias against primary care and cognitive services. Health Affairs Scholar. “Insurance Acceptance and Cash Pay Rates for Psychotherapy in the US.” 2023. Empirical research on out-of-network utilization in mental health care. Medicare Payment Advisory Commission (MedPAC). “Report to the Congress: Medicare and the Health Care Delivery System.” 2024. Annual policy recommendations including proposals for reforming physician fee schedule methodology. Joel Blackstock, LICSW-S, is the Clinical Director of Taproot Therapy Collective in Hoover, Alabama. He specializes in complex trauma treatment and writes at GetTherapyBirmingham.com.
United States v. Ferguson, No. 24-2178 (8th Cir. Jan. 6, 2026)cocaine isomers; divisibility; modified categorical approach; realistic probability test; Arkansas; Ark. Code Ann. § 5-64-401(a)(1)(A)(i)Fofana v. Noem, et al., No. 24-2485 (8th Cir. Jan. 9, 2026)jurisdiction; Patel; INA § 242(a)(2)(B)(ii); asylee adjustment; “any decision” Aguilar-Hernandez v. Bondi, No. 24-2427 (8th Cir. Jan. 6, 2026)domestic violence-type asylum; one central reason; women; acquiescence; Guatemala Gutierrez-Mikan, et al v. U.S. Att'y Gen., No. 24-13788 (11th Cir. Jan. 5, 2026)ineffective assistance of counsel; Loper Bright & Lozada; substantial compliance; CAT; acquiescence; FARC; Colombia Savane v. DHS, et al., No. 24-3286 (3d Cir. Jan. 7, 2026)material misrepresentation; naturalization; willful; diversity visa lottery; DS-230 omissions; omitting children from application; public charge; 8 C.F.R. § 103.2(a)(2); lawfully admitted for permanent residence Matter of E-M-F-S-, 29 I&N Dec. 379 (BIA 2026)death threats; past persecution; journalists; Peru Liz's email: emontano@kktplaw.comKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
Little v. Hecox | 01/13/26 | Docket #: 24-38 24-38 LITTLE, GOVERNOR OF IDAHO V. HECOX DECISION BELOW: 104 F.4th 1061 ORDER OF OCTOBER 20, 2025: RESPONDENT'S REQUEST THAT THE COURT DISMISS THE CASE AS MOOT IS DEFERRED PENDING ORAL ARGUMENT. SEE ACHESON HOTELS, LLC v. LAUFER , 601 U. S. 1, 4 (2023). CERT. GRANTED 7/3/2025 QUESTION PRESENTED: Women and girls have overcome decades of discrimination to achieve a more equal playing field in many arenas of American life-including sports. Yet in some competitions, female athletes have become bystanders in their own sports as male athletes who identify as female have taken the place of their female competitors-on the field and on the winners' podium. The Idaho Legislature addressed that injustice by enacting the Fairness in Women's Sports Act, which ensures that women and girls do not have to compete against men and boys no matter how those men and boys identify. The Act-one of 25 such state laws around the country-is consistent with longstanding government policies preserving women's and girls' sports due to the "average real differences" between the sexes. Clark ex rel. Clark v. Ariz. Interscholastic Ass'n, 695 F.2d 1126, 1131 (9th Cir. 1982). Breaking with this Court's precedents, its own caselaw, other circuit decisions, and biological reality, the Ninth Circuit panel here upheld an injunction against the Act because it prevents "transgender women and girls"-meaning males who identify as women and girls-from competing in "women's student athletics." App.4a-5a. The question presented is: Whether laws that seek to protect women's and girls' sports by limiting participation to women and girls based on sex violate the Equal Protection Clause of the Fourteenth Amendment. LOWER COURT CASE NUMBER: 20-35813, 20-35815
OA1225 - Jenessa is here to dig deeper into Van Buren v. United States as we explore the implications and meaning when legislative deliverables, legal analysis, work industry, and general common sense push and pull in different directions. We had a lot of questions and comments on the original Van Buren episode from the community, so we thought it would be fun to spend some more time and battle it out! Reviving Lenity - Daniel Harawa, SCOTUSBlog (Dec 26, 2025) US v Rodriguez, 628 F.3d 1258 (11th Cir. 2010) US v Nosal, 676 F.3d 754 (9th Cir. 2012) US v Nosal, 844 F.3d 1024 (9th Cir. 2016) Further reading: W. Cagney McCormick, The Computer Fraud & Abuse Act: Failing to Evolve with the Digital Age, 16 SMU SCI. & TECH. L. REV. 481 (2013). Check out the OA Linktree for all the places to go and things to do!
In this special documentary episode, Patrick Gray and Amberleigh Jack take a historical dive into hacking in the 1980s. Through the words of those that were there, they discuss life on the ARPANET, the 414s hacking group, the Morris Worm, the vibe inside the NSA and a parallel hunt for German hackers happening at a similar time to Cliff Stoll's famous Cuckoo's Egg story. This podcast features the memories of: Jon Callas, former principal software engineer at Digital Equipment Corporation Mark Rasch, Morris Worm prosecutor Timothy Winslow, former 414 hacker Greg Chartrand, author of Cracking the Cuckoos Egg and Tony Sager, former NSA How the World Got Owned is produced in partnership with SentinelOne. Show notes 1988 Federal sentencing guidelines manual Computer Intruder is put on probation and fined $10,000 | The New York Times Computer Intruder is found guilty | The New York Times United States of America, Appellee, v. Robert Tappan Morris, Defendant-appellant, 928 F.2d 504 (2d Cir. 1991) The Cuckoo's Egg: Tracking a Spy Through the Maze of Computer Espionage | Clifford Stoll Cracking the Cuckoo's Egg: The Untold Story of tracking and finding Karl Koch aka Hagbard of the Chaos Computer Club | Greg Chartrand Computer Buffs Tapped NASA Files | The New York Times Young Computer Bandits Byte off More than They Could Chew | The Washington Post ‘Hacker' is used by Mainstream Media, September 5, 1983 | EDN Neal Patrick to testify before congressional committee Wargames official trailer, 1983 CBS News Segment on Robert Morris Computer Hacker The Fall of the Berlin Wall | Sky News I Hacked a Nuclear Facility in the 1980's. You're Welcome | CNN
Guest Keri Barron, PhD, RN, CNE, shares ideas for improving cardiovascular outcomes for Black women. This includes individual actions such as preparation for clinical encounters and self-advocacy, as well as larger-scale initiatives like research and community outreach.Resources & References:PCNA articles: Faith-Based Cardiovascular Health. https://pcna.net/news/faith-based-cardiovascular-health/Understanding the Essentials: Cardiovascular Nurses in Community Outreach. https://pcna.net/news/understanding-the-essentials-cardiovascular-nurses-in-community-outreach/ Cushman M, Shay CM, Howard VJ, et al. G10-Year Differences in Women's Awareness Related to Coronary Heart Disease. Circulation.2020. DOI: 10.1161/CIR.0000000000000907.See Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.
Matter of Ghanbari, 29 I&N Dec. 376 (BIA 2025)· bond; mandatory detention; material support to a terrorist organization; propaganda; non-violent conductRamos-Hernandez v. Bondi, No. 25-1038 (1st Cir. Dec. 22, 2025)· asylum; withholding of removal; Guatemala; particular social group; family-based; business ownership; persecution; isolated eventsCampuzano v. Bondi, No. 24-60575 (5th Cir. Dec. 22, 2025)· authentication of criminal records; INA § 240(c)(3)(C); crime of child abuse; INA § 237(a)(2)(E)(i); categorical approach; modified categorical approachRuiz v. Bondi, No. 23-1095 (9th Cir. Dec. 22, 2025)· jurisdiction; extraordinary circumstances; INA § 208(a)(2)(D); one-year filing deadline; 8 U.S.C. § 1252(a)(2)(D); mixed questions; discretion; asylum; withholding of removal; administrative closureKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
Drs Harrington and Gibson's annual review of cardiovascular medicine: ACS guidelines, antiplatelet management, GLP-1s, and ever lower LDL-C with drugs or even gene editing are among the highlights. This podcast is intended for healthcare professionals only. To read a transcript or to comment, visit https://www.medscape.com/author/bob-harrington New ACS Guidelines 2025 ACC/AHA/ACEP/NAEMSP/SCAI Guideline for the Management of Patients With Acute Coronary Syndromes https://doi.org/10.1161/CIR.0000000000001309 ACS Guideline Chair and Vice-Chair Discussion https://www.medscape.com/viewarticle/acs-guidelines-2025-key-points-chair-and-vice-chair-2025a100093l Antiplatelet/Antithrombotic Strategies Prasugrel Beats Ticagrelor in High-Risk Patients With Diabetes After PCI https://www.medscape.com/viewarticle/prasugrel-beats-ticagrelor-high-risk-patients-diabetes-after-2025a1000wbt Early Withdrawal of Aspirin after PCI in Acute Coronary Syndromes (NEO-MINDSET) https://www.nejm.org/doi/full/10.1056/NEJMoa2507980 Aspirin in Patients with Chronic Coronary Syndrome Receiving Oral Anticoagulation (AQUATIC) https://www.nejm.org/doi/full/10.1056/NEJMoa2507532 Bayesian Machine Learning Model Guiding Iterative, Personalized Anticoagulant Dosing Decision-Making : ENGAGE AF-TIMI 48 Trial Analysis https://doi.org/10.1016/j.jacadv.2025.102504 Factor XI Inhibitors Bristol Myers, J&J Stop Blood Clotting Drug Trial After Interim Review https://www.medscape.com/s/viewarticle/bristol-myers-j-j-stop-blood-clotting-drug-trial-after-2025a1000vqu Bayer's Asundexian Met Primary Efficacy and Safety Endpoints in Landmark Phase III OCEANIC-STROKE Study in Secondary Stroke Prevention https://www.bayer.com/en/us/news-stories/oceanic-stroke OAC-Naive Subgroup From OCEANIC-AF Published https://www.medscape.com/viewarticle/novel-blood-thinner-shows-promise-atrial-fibrillation-2025a10008lz GLP-1 and Myotrophic Drugs Lilly's Next-gen Drug Shows Greater Weight Loss Than Zepbound in Late-stage Trial (TRIUMPH-4) https://www.medscape.com/s/viewarticle/lillys-next-gen-drug-tops-zepbound-weight-loss-late-stage-2025a1000ys1 Amylin Analog Eloralintide Reduces Weight in Phase 2 Trial https://www.medscape.com/viewarticle/amylin-analog-eloralintide-reduces-weight-phase-2-trial-2025a1000uqf CRISPR and Lipid Lowering Patient-Specific In Vivo Gene Editing to Treat a Rare Genetic Disease https://www.nejm.org/doi/full/10.1056/NEJMoa2504747 Gene Therapy Shows Lipid Improvement but Raises Flags https://www.medscape.com/viewarticle/gene-therapy-shows-lipid-improvement-raises-flags-2025a1000uzw Phase 1 Trial of CRISPR-Cas9 Gene Editing Targeting ANGPTL3 https://www.nejm.org/doi/full/10.1056/NEJMoa2511778 Evolocumab in Patients without a Previous Myocardial Infarction or Stroke (VESALIUS-CV) https://www.nejm.org/doi/pdf/10.1056/NEJMoa2514428 Prehospital GLP IIb/IIIa Zalunfiban at First Medical Contact for ST-Elevation Myocardial Infarction (CELEBRATE) https://evidence.nejm.org/doi/full/10.1056/EVIDoa2500268 You may also like: Hear John Mandrola, MD's summary and perspective on the top cardiology news each week, on This Week in Cardiology https://www.medscape.com/twic Questions or feedback, please contact news@medscape.net
OA1220 - What's an FBI agent to do when a notorious low life reports a local cop is asking for a bribe? Turn him into a confidential information of course, and see how far you can get that dirty cop to go. A tale of two assholes, steadily making each others' lives worse and worse, while one is wearing a wire. Now, why does the Supreme Court care about any of this? Half the conviction hinges on whether this cop “exceeded authorized access” under the Computer Fraud and Abuse Act (CFAA), and no one can agree what that means… including your cohosts. Hear Thomas try to figure out why Amy Coney Barrett is so obsessed with the definition of the word “so”, and Jenessa… defend Clarence Thomas?! This case is a hot mess, but the good news is everyone sucks here and no one wins. The relevant language: “The Act subjects to criminal liability anyone who “intentionally accesses a computer without authorization or exceeds authorized access,” and thereby obtains computer information. 18 U. S. C. §1030(a)(2). It defines the term “exceeds authorized access” to mean “to access a computer with authorization and to use such access to obtain or alter information in the computer that the accesser is not entitled so to obtain or alter.” §1030(e)(6).” Barrett's ruling: “In sum, an individual “exceeds authorized access” when he accesses a computer with authorization but then obtains information located in particular areas of the computer—such as files, folders, or databases—that are off limits to him.” Van Buren v. United States, 593 U.S. 374 (2021) United States v. Van Buren, 940 F.3d 1192 (11th Cir. 2019) Full text of the CFAA: 18 U.S.C. § 1030 Check out the OA Linktree for all the places to go and things to do!
CardioNerds (Dr. Colin Blumenthal, Dr. Kelly Arps, and Dr. Natalie Marrero) discuss anti-arrhythmic drugs in the management of atrial fibrillation and atrial flutter with electrophysiologist Dr. Andrew Epstein. We discuss two major classes of anti-arrhythmic drugs, class IC and class III, as well as digoxin. Dr. Epstein explains their mechanisms of action, indications and specific patient populations in which they would be particularly helpful, efficacy, adverse side effects, contraindications, and key drug-drug interactions. We also elaborate on defining clinical trials and their clinical implications. Given the large burden of atrial fibrillation and atrial flutter in our patient population and the high prevalence of anti-arrhythmic drug use, this episode is sure to be applicable to many practicing physicians and trainees. Audio editing by CardioNerds academy intern, Grace Qiu. Enjoy this Circulation 2022 Paths to Discovery article to learn about the CardioNerds story, mission, and values. CardioNerds Atrial Fibrillation PageCardioNerds Episode PageCardioNerds AcademyCardionerds Healy Honor Roll CardioNerds Journal ClubSubscribe to The Heartbeat Newsletter!Check out CardioNerds SWAG!Become a CardioNerds Patron! Pearls Anti-arrhythmic drugs should not be thought of as an alternative to ablation but, instead, should be considered an adjunct to catheter ablation. Class IC anti-arrhythmic drugs, flecainide and propafenone, are highly efficacious for acute cardioversion and a great option for patients with infrequent episodes of AF who do not have a history of ischemic heart disease. Class III anti-arrhythmic drugs like ibutilide, sotalol, and dofetilide, are highly effective for acute conversion; however, they require hospitalization for close monitoring during initiation and dose titration given the risk of prolonged QT. Amiodarone should not be used as a first line agent given its toxicities, prolonged half-life, large volume of distribution, and drug-drug interactions. Dr. Epstein notes that, “All drugs are poisons with a few beneficial side effects,” when highlighting the many adverse side effects of anti-arrhythmic drugs, particularly amiodarone, and the importance of balancing their benefit in rhythm control with their side effect profile. Notes Notes: Notes drafted by Dr. Natalie Marrero. What are the Class IC anti-arrhythmic drugs and what indications exist for their use? Class IC anti-arrhythmic drugs are anti-arrhythmic drugs that work by blocking sodium channels and, thereby, prolonging depolarizing. Class IC anti-arrhythmic drugs include flecainide and propafenone. Class IC anti-arrhythmic drugs are good agents to use in patients that have infrequent episodes of AF and do not want daily dosing as these agents can be used by patients when they feel palpitations and desire acute conversion back to sinus rhythm (“pill in the pocket” approach). What are the adverse consequences and/or contraindications to using a class IC agent? Class IC anti-arrhythmic agents are contraindicated in patients with a history of ischemic heart disease based on increased mortality associated with their use in these patients in the CAST trial. Given the results of the CAST trial, providers should screen annually for ischemia via a functional stress test in patients on these drugs at risk for coronary disease. These drugs can increase 1:1 conduction of atrial flutter and, therefore, require concomitant use of a beta blocker. These agents are generally well-tolerated without any organ toxicities; however, they can precipitate heart failure in patients with cardiomyopathies, cause sinus node depression, and unmask genetic arrythmias such as a Brugada pattern. What are the class III agents and what are indications for their use? Class III agents are drugs that block the potassium channel, prolonging the QT, and include Ibutilide, Sotalol, and Dofetilide. Class III agents can be considered in patients with or without a history of ischemic heart disease that desire effective acute chemical cardioversion and are willing to go to the hospital for close monitoring during dose initiation and titration. Other specific circumstances in which one can use these agents, specifically Ibutilide, are in patients with recurrent atrial fibrillation and Wolf Parkinson White (due to slowed conduction via the accessory pathway). What are the adverse consequences and/or contraindications to using a class III agent? Ibutilide, Sotalol, and Dofetilide prolong the QT and increase the risk of torsade de pointes, which is why they require ECG monitoring in-patient during drug initiation and dose titration. These agents are generally well-tolerated. Sotalol should be avoided or used cautiously in patients with left ventricular dysfunction, while dofetilide can be used and has dose-response beneficial effects in patients with left ventricular dysfunction. Both sotalol and dofetilide are renally cleared with specific creatinine clearance cutoffs (CrCl < 20 for dofetilide and CrCl
Matter of Tepec-Garcia, 29 I&N Dec. 371 (BIA 2025)termination; in absentia; DHS burden to prove alienage Matter of L-A-G-B-, 29 I&N Dec. 339 (BIA 2025)Panama cartels; CAT; snitches; series of suppositions Matter of Kim, 29 I&N Dec. 339 (BIA 2025)LPR cancellation of removal; discretion; criminal history; South Korea Matter of Lema Mizhirumbay, 29 I&N Dec. 351 (BIA 2025)discretion; weighing factors; criminal history; OSHA violations Matter of N-P-A-, 29 I&N Dec. 347 (BIA 2025)de novo; well-founded fear; ability to freely leave country; pretextual summons; Moldova Matter of Rodriguez Pena, 29 I&N Dec. 358 (BIA 2025)bond; dangerousness; threats; false claim to citizenship; victim affidavits; dismissed criminal charges Matter of Palma-Olvera, 29 I&N Dec. 355 (BIA 2025)good moral character; DUI; Castollo-Perez; rebutting presumption Sanik Herrera v. Bondi, No. 25-3207 (6th Cir. Dec. 15, 2025)motion to reopen; exhaustion; due process; sua sponte Liao v. Bondi, No. 25-60427 (5th Cir. Dec. 17, 2025)untimely petition for review; mandatory claims processing rule; Riley; prison mailbox rule; affidavits Matter of L-T-A-, 29 I&N Dec. 362 (BIA 2025) firm resettlement; some other type of permanent resettlement; A-G-G-Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
“How can I return to the Church?” This question is central for many facing addiction and recovery. In this episode, we also address concerns about balancing church attendance with recovery meetings, the role of the 12-step program in relation to Catholicism, and the nature of compulsions in alcoholism. Join the Catholic Answers Live Club Newsletter Invite our apologists to speak at your parish! Visit Catholicanswersspeakers.com Questions Covered: 03:00 – How does someone with addiction come back to Church? 12:30 – I have a sponsor who thinks I'm going to Church too much and not enough to attend meetings. What is your advice? 18:38 – I have a brother in recovery. Is the 12-step program a substitute for Catholicism? 23:08 – How common are compulsions in alcoholism? Can they eventually become an OCD problem? 30:35 – Why do AA meetings refer to God as high power? 37:23 – How do you stay sober? 41:40 – I’ve been to CIR meetings, I love the fact that it is Catholic! 45:20 – What’s your opinion on Anne Grace and the help she offers? 49:16 – I'm a recovering addict and am Catholic. What ways do you think we can build our community back in 12-step programs? 52:32 – Have you read Fulton Sheen’s description of alcoholism?
Osabas-Rivera v. Bondi, No. 25-3168 (6th Cir. Dec. 8, 2025)untimely asylum filing; jurisdiction; satisfaction of the attorney general; exhaustion Matter of Jimenez-Ayala, 29 I&N Dec. 325 (BIA 2025)LPR cancellation; discretion; insufficient rehabilitation; use of meth Matter of W-F-, 29 I&N Dec. 319 (BIA 2025)CAT; particularly serious crime; mental health; B-Z-R-; Haitian prisons; Brian Concannon; gang violence; acquiescence Matter of J-C-A-G-, 29 I&N Dec. 331 (BIA 2025)Mexican cartels; CAT; snitches; more likely than not; police; CJNG cartel; Sinaloa cartel Matter of Dubon Miranda, 29 I&N Dec. 335 (BIA 2025)bond; dangerousness; dismissed convictions; allegations against a child victim; DUI; evasive testimonyKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Stafi"Remote staffing solutions for businesses of all sizes"Click me!Want to become a patron?Click here to check out our Patreon Page!CONTACT INFORMATION:Email: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
In this episode the SCT Brothers give their cogent analysis about Sean Combs: The Reckoning, a docu-series executive produced by 50 Cent. We also discuss our 2025 apple music replays, and talk about some future moves for the pod.
Bienvenida de nuevo al Planeta Parto. Hoy vas a conocer a Mari Carmen, que nos cuenta el camino que recorrió hasta tener en brazos a su niña Jimena en Diciembre de 2023. Mari Carmen empezó la búsqueda a los 41 años recurriendo a la reproducción asistida. Hizo 5 transferencias hasta quedarse embarazada, y debido a su edad le hicieron un seguimiento de alto riesgo. En la semana 22 le diagnosticaron un CIR (crecimiento intrauterino retardado), y en la semana 36+1 rompió bolsa. En el hospital empezaron la inducción, y el expulsivo acabó con una episiotomía y fórceps. La niña estuvo 15 días en neonatos hasta ganar suficiente peso. Un testimonio final feliz, con un mensaje esperanzador para muchas mujeres que buscan la maternidad pasados los 40 años. Clica PLAY y empezamos!
Pineda-Guerra v. Bondi, No. 25-3081 (6th Cir. Dec. 3, 2025)change of attorney address; BIA summary dismissal; BIA abuse of discretion where requirements not contained in Practice Manual or regulations Restrepo Castano v. Bondi, No. 24-2117 (1st Cir. Nov. 28, 2025)unable or unwilling to protect; fruitful police protection; phone threats; Gulf Clan; Colombia Dor v. Bondi, No. 25-1278 (1st Cir. Dec. 1, 2025)controlled substance offense; comparison with CSA at time of conviction; Massachusetts marijuana; hemp De La Cruz-Quispe v. Bondi, No. 25-1421 (1st Cir. Dec. 5, 2025)nexus; domestic violence type asylum claim; personal vendetta; Peru Silva de Santiago v. Bondi, No. 25-60064 (5th Cir. Dec. 4, 2025)abuse of a child under New Mexico Revised Statute § 30-6-1(D); crime of child abuse, neglect, or abandonment; exposing child to inclement weather; realistic probability test in the Fifth Circuit; stop time rule & INA § 212(a)(2)(B); LPR cancellation of removal B. Singh v. Bondi, No. 24-815 (9th Cir. Dec. 1, 2025)past persecution; beatings; threats; reasonable relocation in India; Law Library of Congress report; Mann Party; Sikh Cristales-de Linares v. Bondi, No. 25-3152 (6th Cir. Dec. 1, 2025)particularity; particular social group; women; employment and economic factors; failure to identify attackers; relocation; Tista-Ruiz; gangs; extortion; El SalvadorKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerSupport the show
The Immigration Lawyers Podcast | Discussing Visas, Green Cards & Citizenship: Practice & Policy
Host John Q. Khosravi, Esq. sits down with Kevin A. Gregg, Esq. of KKTP and host of the Immigration Review Podcast for their monthly deep-dive into the most significant immigration law developments. In this episode, John and Kevin break down three major new cases—spanning habeas, EAJA fees, crim-imm, and asylum law—while also discussing consular processing trends, USCIS/ICE coordination concerns, AILA conferences, and the realities of practicing immigration law during turbulent times. Whether you're here to stay sharp, stay current, or stay inspired, this episode delivers powerful insights every immigration lawyer should hear. Spotify | iTunes | YouTube Music | YouTube Timestamps: 00:00 — Opening 00:33 — Introduction 02:35 — AILA California Chapters Conference 07:01 — Improving Podcast Quality 09:31 — Daley v. Choate, No. FEDERICO (10th Cir. 2025) 18:31 — United States v. Miller, No. 23-13069 (11th Cir. 2025) 25:47 — Ramos Marquez v. Bondi, No. 24-1842 (4th Cir. Nov. 19, 2025) 29:27 — Closing Remarks 39:03 — Closing Live Consular Processing training for lawyers Dec 18, 10:00–11:45 a.m. PT - NVC packets & DS-260 - Interview prep & follow-up - Timelines, fees, and real-world workflows Register here! Follow eimmigration by Cerenade: Facebook | Instagram | LinkedIn Start your Business Immigration Practice! (US LAWYERS ONLY - SCREENING REQUIRED): E-2 Course EB-1A Course Get the Toolbox Magazine! Join our community (Lawyers Only) Get Started in Immigration Law! The Marriage/Family-Based Green Card course is for you Our Website: ImmigrationLawyersToolbox.com Not legal advice. Consult with an Attorney. Attorney Advertisement. #podcaster #Lawyer #ImmigrationLawyer #Interview #Immigration #ImmigrationAttorney #USImmigration #ImmigrationLaw #ImmigrationLawyersToolbox
Perez-Perez v. Bondi, No. 25-0315 (6th Cir. Nov. 21, 2025)qualifying relative age-out for non LPR cancellation of removal purposes; meaning of the phrase “would result”; Loper Bright; freezing age at time of IJ adjudication Sarkisov v. Bondi, No. 25-0316 (6th Cir. Nov. 21, 2025)extraordinary circumstances for VAWA-based motions to reopen; mixed question of law and fact review; definition of extraordinary circumstances; psychological harm Labrador Gutierrez v. Bondi, No. 25-60646 (5th Cir. Nov. 26, 2025)stay of removal; Nken B.G.S. v. Bondi, No. 23-6862 (2d Cir. Nov. 24, 2025)government acquiesce; MS-13; Guatemala; former gang members; tattoos; prison conditions; Green Light order; prison guard consent; speculation expected with CAT Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/Want to become a patron?Click here to check out our Patreon Page! CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego Voyager DISCLAIMER & CREDITSSee Eps. 1-200Support the show
Afib is on the rise with significant effects on morbidity and mortality. Afib is a progressive disease with various treatment methods to match to your patients' risk factors and health goals. Stroke prevention is a crucial risk factor to evaluate on the progressive journey of a patient experiencing Afib. Learn more about the assessment and identification of patients with Afib at risk for stroke and next steps in prevention.https://www.ahajournals.org/doi/10.1161/CIR.0000000000001193https://chads2vasccalculator.com/https://www.uptodate.com/contents/image?imageKey=HEME%2F75259https://pcna.net/resource/afib-prepare-for-your-next-visit-discussion-guide/https://pcna.net/resource/the-beat-goes-on-living-with-atrial-fibrillation-online-interactive-patient-guide/https://pcna.net/resource/afib-and-stroke-infographic/See Privacy Policy at https://art19.com/privacy and California Privacy Notice at https://art19.com/privacy#do-not-sell-my-info.
In this episode, host Sloan Simmons joins Title IX experts Sarah Fama and Sinead McDonough for a comprehensive discussion regarding the status of the law as it pertains to gender identity, students, and schools. Topics covered include the current status of California and federal law and policy on point, as well as the wide-ranging scope of pending litigation poised to impact this area of school law. Show Notes & References 1:54 – Foundational cases impacting Title IX policy (Bostock v. Clayton County (2020) 140 S. Ct. 1731) (Client News Brief 50 - June 2020) 2:55 – Grabowski v. Arizona Board of Regents (9th Cir. 2023) 69 F.4th 1110 5:51 – Parents for Privacy vs. Barr (9th Cir. 2020) 949 F.3d 1210 (Client News Brief 40 - May 2020) 10:48 – Roe vs. Critchfield (9th Cir. 2025) 137 F.4th 912 (Client News Brief 14 - April 2025) 12:49 – Jones, et al. v. Critchfield, et al., Ninth Circuit Case No. 25-5413 13:44 – Regino vs. Blake (formerly Staley) (9th Cir. 2025) (Client News Brief 17 - April 2025) 14:57 – Assembly Bill (AB) 1266 20:00 – United States v. Skrmetti (2025) 605 U.S. 495 22:24 – The law in California 23:25 – CIF (California Interscholastic Federation) Rule 300D and Guidelines for Gender Identity Participation 24:36 – Interactions with federal law 25:56 – Executive Order (EO) 14168 (Client News Brief 12 - February 2025) 27:01 – Tennessee v. Cardona decision 28:29 – Dear Colleague letter - February 4, 2025 30:32 – Federal government's approach and reaction to CIF and AB 1266 (USDOE Press Releases: February 12, 2025; March 27, 2025; June 25, 2025) 34:00 – Related Supreme Court cases (Little v. Hecox, Case No. No. 24-38; West Virginia v. B.P.J., Case No. 24-43) 35:09 – T.S. et al. v. Riverside Unified School District et al., U.S.D.C., Central District of California, Case No. 5:24-cv-02480-SSS-SP, and order on motion to dismiss, (C.D. Cal. Sept. 24, 2025) 2025 WL 2884416 36:25 – Protections for student privacy and their interactions with parental rights 39:22 – Mirabelli vs. Olson et al.¸U.S.D.C., Southern District of California, Case No. 3:23-cv-00768-BEN-VET 40:00 – The SAFETY Act (AB 1955) 44:13 – The dynamic between the federal government and California post-AB 1955 enactment (United States of America v. California Interscholastic Federation et al., U.S.D.C., Central District of California, 8:25-cv-01485-CV-JDE) 50:26 – Foote v. Ludlow School Committee, Case No. 25-77 52:19 – Mahmoud v. Taylor (2025) 606 U.S. 522 (Listen to Episode 97 Mahmoud v. Taylor) (Client News Brief 28 - July 2025) 53:31 – Access to facilities 55:15 – Grimm v. Gloucester County School Board (4th Cir. 2020) 972 F.3d 586 56:06 – Million Dollar Question: Does Title IX protect individuals based on gender identity or not? For more information on the topics discussed in this podcast, please visit our website at: www.lozanosmith.com/podcast
Ramos Marquez v. Bondi, No. 24-1842 (4th Cir. Nov. 19, 2025) unable or unwilling to protect; relocation; police failure to arrest; futile reporting to police; agency ignoring evidence; cherry picking; CAT; quiescence; MS-130; Honduras state of exception; country condition evidence in Honduras Matter of K-S-H-, 29 I&N Dec. 307 (BIA 2025) unable or unwilling to protect; single incident where police fail to investigate; Sikh asylum; relocation in India Matter of B-S-H-, 29 I&N Dec. 313 (BIA 2025) VAWA-based motion to reopen; motion to reconsider; number and temporal limitations on VAWA-based motions to reopen; prima facie VAWA letter Kazarian v. Bondi, No. 25-4427 (9th Cir. Nov. 18, 2025) FRAP 3(c)(1)(B) and 15(a)(2)(C); attaching BIA decision to PFR; excusing appellate requirements for pro se noncitizens; 8 U.S.C. § 1252(c); FRAP not claims processing rule Luna-Corona v. Bondi, No. 24-9522 (10th Cir. Nov. 17, 2025) good moral character; DUI; recidivist behavior; considering conduct outside statutory period McLean v. Bondi, No. 20-61098 (5th Cir. Nov. 20, 2025) crime of violence aggravated felony; threatened use of force; divisibility; different punishments; 18 U.S.C. § 115(a)(1); influencing a federal official by threatImmigrants' List Ads!Is Your City Next? (National Guard) Follow the Money (Mass Detention)Not Criminals (Agriculture)Stop the Spike (ACA Tax Credits)For No Good Reason (Wasteful govt spending)Stop Playing Politics With Our Children's Health (vaccinations)Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Special Link! Stafi"Remote staffing solutions for businesses of all sizes"Promo Code: STAFI2025Click me! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewSupport the show
An Interview with Todd Gaziano, President, Center for Individual Rights At a time when constitutional rights face continuing pressures---from campus censorship to race-based government policies---one organization has spent the last 35 years winning legal battles that set lasting precedents for individual liberty. The Center for Individual Rights was founded in 1989 to defend constitutional principles through strategic litigation. Its first major Supreme Court victory, Rosenberger v. University of Virginia in 1995, established that public universities cannot discriminate based on religious viewpoint---a principle that continues to influence cases to this day. CIR also secured landmark victories challenging race-based admissions policies in the University of Michigan cases. Our guest on this episode of Voices of Freedom is Todd Gaziano, who became CIR's president in 2023. Before joining CIR, he led legal centers at both the Pacific Legal Foundation and the Heritage Foundation, served as a commissioner on the U.S. Commission on Civil Rights, and worked in the Justice Department's Office of Legal Counsel and as chief counsel to a House subcommittee. He discusses CIR's strategic approach to defending equal protection, religious liberty, free speech, and competitive federalism---and explains why these constitutional battles matter for every American. Topics Discussed on this Episode: Todd's path to the Center for Individual Rights and the most urgent threats to constitutional rights today The 30-year legacy of Rosenberger v. University of Virginia and its impact on campus free speech CIR's current cases challenging race-based policies in Portland schools and within federal programs Religious liberty and competitive federalism: why these areas matter Concerns and hopes for the future of constitutional rights in America
Matter of Cahuec Tzalam, 29 I&N Dec. 300 (BIA 2025)Special Immigration Juvenile Status; administrative closure; requirement to establish prima facie eligibility; some foreseeable resolution; visa bulletin; 8 C.F.R. § 1003.18(c)(3) Solis-Flores v. Bondi, No. 22-1147 (4th Cir. Nov. 13, 2025)receipt of stolen property CIMT; VA Code § 18.2-108; realistic probability test; Loper Bright; CIMT definition in the Fourth CircuitKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Homepage!Demo Link!Get the Guide! Stafi"Remote staffing solutions for businesses of all sizes"Promo Code: STAFI2025Click me! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/ Want to become a patron?Click here to check out our Patreon Page! CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerDISCLAIMER & CREDITSSee Eps. 1-200Support the show
Daley v. Choate, et al., No. 24-1191 (10th Cir. Nov. 3, 2025)EAJA; habeas; sovereign immunity canon; Loper Bright; civil action; importance of habeas Martinez-Martinez v. Bondi, No. 241464 (4th Cir. Nov. 5, 2025)false testimony; INA § 101(f)(6); BIA review of missed questions of law and fact; Wilkinson; Patel; jurisdiction; failure to disclose alias Rosa Arevalo v. Bondi, Nos. 24-60349, 24-60620 (5th Cir. Nov. 5, 2025)Illinois law vacating criminal conviction for procedural or substantive defect; motion to reopen; due diligence; equitable tolling Dominguez Reyes v. Bondi, No. 25-60016 (5th Cir. Nov. 6, 2025)INA § 101(a)(43)(D) aggravated felony; circumstance specific approach; Matter of Babaisakov; tethered to offense; contesting forfeiture; profit not material Calderon-Uresti v. Bondi, No. 24-60445 (5th Cir. Nov. 6, 2025)VAWA cancellation of removal; extreme cruelty; failure to corroborate credible testimony; exhaustion United States v. Miller, 23-13069 (11th Cir. Nov. 6, 2025)sentence enhancement; ACCA; Florida cocaine derivative; categorical approach point of comparison Iuflopane; drug definition at point of committing the offenseKurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Homepage!Demo Link!Get the Guide! Stafi"Remote staffing solutions for businesses of all sizes"Promo Code: STAFI2025Click me! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com EB-5 Support"EB-5 Support is an ongoing mentorship and resource platform created specifically for immigration attorneys."Contact: info@eb-5support.comWebsite: https://eb-5support.com/ Want to become a patron?Click here to check out our Patreon Page! CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreviewAbout your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerDISCLAIMER & CREDITSSee Eps. 1-200Support the show
The Immigration Lawyers Podcast | Discussing Visas, Green Cards & Citizenship: Practice & Policy
In this monthly episode, John Q. Khosravi, Esq. sits down with Kevin A. Gregg, Esq. to break down key new immigration cases and developments from the federal courts. They discuss the latest in: - Notice and due process in Rivera-Valdes (9th Cir.) - Police reports and discretion in Maurice v. Bondi (1st Cir.) - Conspiracy and particularly serious crimes in Amos v. Att'y Gen. (3d Cir.) Plus, Kevin shares updates on habeas litigation trends and practical tips for removal defense attorneys.
#EP317 The solar industry faces a defining moment in Q4 2025. While regulatory challenges create uncertainty, well-capitalized players treat this period as a buying opportunity. Daniel Dus, CEO and founder of Cleantech Industry Resources (CIR), breaks down the market dynamics and explains how his company's global expertise positions it to thrive during industry consolidation.Daniel Dus founded CIR to provide development, construction, and operations services for solar and battery storage projects. His team of 140 professionals across three offices in India and the United States brings proven experience from building some of the world's largest solar installations, including work with Adani Green Energy as it scaled from startup to 16 gigawatts in operation.Key Discussion Points:The current solar market has split into thirds: one-third undercapitalized and struggling, one-third in wait-and-see mode, and one-third aggressively acquiring projects with strong capital backing - creating opportunities for companies like CIR that can execute complex transactions.CIR serves 150 clients across the solar value chain, providing everything from interconnection studies and permit-ready planset packages to full EPC services, with particular expertise in rescuing distressed projects and navigating complex utility requirements.CIR's competitive advantage comes from its India-based technical teams, who have worked on massive international projects, bringing world-class expertise at competitive rates to US developers who struggle with margin compression.Solar Fight Night, Dus's passion project since 2008, has raised nearly $2 million for clean energy nonprofits through 24+ events. The 2025 event at Las Vegas's Zouk Nightclub drew over 3,300 attendees, the largest crowd in the event's history.Tim Montague is an affiliate of CIR and welcomes developers and EPCs to contact him for more information about working with CIR. [Book here: https://calendly.com/tim-montague/30min]Connect with Daniel Dus, CIR LinkedIn: www.linkedin.com/in/danielrdusWebsite: cleantechindustryresources.comSolar Fight Night: www.solarfightnight.org/ Support the showConnect with Tim Clean Power Hour Clean Power Hour on YouTubeTim on TwitterTim on LinkedIn Email tim@cleanpowerhour.com Review Clean Power Hour on Apple PodcastsThe Clean Power Hour is produced by the Clean Power Consulting Group and created by Tim Montague. Contact us by email: CleanPowerHour@gmail.com Corporate sponsors who share our mission to speed the energy transition are invited to check out https://www.cleanpowerhour.com/support/The Clean Power Hour is brought to you by CPS America, maker of North America's number one 3-phase string inverter, with over 6GW shipped in the US. With a focus on commercial and utility-scale solar and energy storage, the company partners with customers to provide unparalleled performance and service. The CPS America product lineup includes 3-phase string inverters from 25kW to 275kW, exceptional data communication and controls, and energy storage solutions designed for seamless integration with CPS America systems. Learn more at www.chintpowersystems.com
United States v. Ford aka Caveman, No. 23-1400 (10th Cir. Oct. 28, 2025)crime of violence; kidnapping; inveigling; federal definition despite no cross reference to federal statute Matter of C-I-G-M- & L-V-S-G-, 29 I&N Dec. 291 (BIA 2025)third country removal; ACA with Honduras; Immigration Judge authority; 8 C.F.R. § 1240.11(h)Chen, et al. v. Rubio, et al., No. 25-521 (2d Cir. Oct. 29, 2025)doctrine of consular nonreviewability; no constitutional right to live with parent or sibling; Munoz Alfaro-Zelaya v. Bondi, No. 23-2069 (4th Cir. Oct. 31, 2025)failure to consider country condition evidence; femicide; gender-based claims in Honduras Bastias v. U.S. Att'y Gen., No. 21-11416 (11th Cir. Oct. 30, 2025)INA § 237(a)(2)(E)(i) crime of child abuse, abandonment, or neglect; Fla. Stat. § 827.03(2)(d); Loper Bright and views of Judges Newsom, Marcus, and Middlebrooks Sponsors and friends of the podcast!Click here to check out Former IJ David Koelsch and AMDG Law LLC, here: Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Homepage!Demo Link!Get the Guide! Stafi"Remote staffing solutions for businesses of all sizes"Promo Code: STAFI2025Click me! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com Want to become a patron?Click here to check out our Patreon Page! CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreview About your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerDISCLAIMER & CREDITSSee Eps. 1-200Support the show
OA1203 - Happy Halloween! We take shelter from a year of ghoulish legal news in the COURTHOUSE OF HORROR, a cabinet of macabre legal curiosities including: “SO I TRADEMARKED AN AXE MURDERER”: The historic Lizzie Borden House takes a whack at a nearby coffee shop “THE BONE DETECTOR”: Recent patent bar survivor Jenessa Seymour brings us the unbelievable story of the spookiest--and silliest!--lie detector ever registered by the US Patent & Trademark Office “ATTACK OF THE TORTIOUS CLOWNS”: Can you sue a haunted house for your fright-related injuries? “THE GREENBRIER GHOST”: The bizarre tale of how a victim's testimony from beyond the grave helped to convict her killer in an 1896 West Virginia murder trial “CANDYMAN 5: SUMMARY JUDGMENT”: In a tasty conclusion to last year's Halloween footnote on consumers disappointed with the spookiness of their seasonal treats, a Florida federal judge finds as a matter of law that there is no wrong way to make a Reese's. Finally, we close on a serious note with Jenessa's guide to how every registered voter can do their part next week to change the plot of our ongoing American horror story. Order in Ghost Adventures LLC v. Miss Lizzie's Coffee, LLC, No. 23-2000 (1st Cir.)(Selya, J.)(11/15/2024) “Federal Judge Known for Polysyllabic Prose Dies at 90,” Trip Gabriel, The New York Times, (3/21/2025) “Would You Confess Your Criminal Misdeeds to This Skeleton?,” Cara Giaimo, Atlas Obscura (5/16/2017) “Apparatus for Obtaining Criminal Confessions and Photographically Recording Them,” Patent #1749090, H.A. Shelby (filed 8/10/1927) “The Greenbrier Ghost Reexamined,” Greenbrier Historical Society, Arabeth Balseko (1/20/2022) Summary judgment order in Munoz v. Six Flags St. Louis LLC (10/12/2022)(Wallach, J.) Order granting motion to dismiss in Vidal et al v. The Hershey Company, FLSD No. 24-60831 (9/19/2025)(Damian, J.) “Your Cheat Sheet To The 2025 General Elections,” Daniel Nichanian, Bolts (10/1/2025) Check out the OA Linktree for all the places to go and things to do!
*Content Warning: Institutional child abuse, body-image abuse, disordered eating, attack therapy, cultic abuse, grooming, medical trauma, death, alcohol use disorder, psychological and physical trauma, child labor, distressing themes. *Free + Confidential Resources + Safety Tips: somethingwaswrong.com/resources Snag your ticket for the live Home for the Holidays event here: https://events.humanitix.com/swwxtgi Check out our brand new SWW Sticker Shop!: https://brokencyclemedia.com/sticker-shop *SWW S23 Theme Song & Artwork: The S24 cover art is by the Amazing Sara Stewart Follow Something Was Wrong: Website: somethingwaswrong.com IG: instagram.com/somethingwaswrongpodcast TikTok: tiktok.com/@somethingwaswrongpodcast Follow Tiffany Reese: Website: tiffanyreese.me IG: instagram.com/lookieboo *Sources “DeSisto School.” Unsilenced, www.unsilenced.org/program-archive/us-programs/massachusetts/desisto-school/ “Exhibits in Desisto Investigation.” Scribd, Scribd, www.scribd.com/document/324581177/Exhibits-in-DeSisto-Investigation “Off-Broadway's Inappropriate Extends Again to Jan. 30.” Playbill, Playbill, 2 Dec. 2021, playbill.com/article/off-broadways-inappropriate-extends-again-to-jan-30-com-86238 Radio, WAMC Northeast Public. “Controversial School for Troubled Teens to Close.” WAMC, 16 Feb. 2012, www.wamc.org/new-york-news/2004-04-13/controversial-school-for-troubled-teens-to-close Secretary of Labor, Plaintiff, Appellee, V. A. Michael Desisto, Defendant, Appellee,the Desisto Schools, Inc., Defendant, Appellant.Elizabeth Dole, Secretary of Labor, Plaintiff, Appellant, V. A. Michael Desisto, et al., Defendants, Appellees, 929 f.2d 789 (1st Cir. 1991) :: Justia, law.justia.com/cases/federal/appellate-courts/F2/929/789/124165/
United States v. Tooley, No. 24-5286 (6th Cir. Oct. 23, 2025)Borden; recklessness; crime of violence; wantonly; manslaughter; murder Matter of Negusie, 29 I&N Dec. 285 (A.G. 2025)persecutor bar; asylum and withholding of removal; duress and voluntariness; history of asylum; 1967 protocol; evidentiary burden Matter of J-A-N-M-, 29 I&N Dec. 287 (BIA 2025) IJ authority to terminate withholding-only proceedings; termination; at 8 C.F.R. § 1003.18(d) Rojas-Espinoza, et al. v. Bondi, No. 24-7536 (9th Cir. Oct. 24, 2025)administrative stay of removal; Nken; delay; irreparable harm; likelihood of success on the merits; Ninth Circuit General Order 6.4(c)(1); public interest in removal; asylum; Peru Yupangui-Yunga v. Bondi, No. 23-6522 (2d Cir. Oct. 24, 2025)non-LPR cancellation of removal; age out; exhaustion; anticipating arguments not requiredSponsors and friends of the podcast!Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Homepage!Demo Link!Questions to ask! Stafi"Remote staffing solutions for businesses of all sizes"Promo Code: STAFI2025Click me! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com Want to become a patron?Click here to check out our Patreon Page! CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreview About your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerDISCLAIMER & CREDITSSee Eps. 1-200Support the show
The Immigration Lawyers Podcast | Discussing Visas, Green Cards & Citizenship: Practice & Policy
This week's Immigration Lawyers Toolbox® Podcast with John Q. Khosravi, Esq. covers the latest immigration law updates, USCIS trends, and practice tips. Recorded live every Monday, this series keeps attorneys sharp and informed. Timestamps: 00:00 – Opening 03:39 – Government Shutdown Update 04:17 – USCIS Adds $1,000 Parole Fee for DACA 05:01 – 9th Cir. Pushback on “Imperial Judiciary” Criticism 05:45 – Ninth Circuit Upholds Injunction Protecting Counsel for Unaccompanied Minors 06:25 – U.S. Revokes Visas Over Charlie Kirk-Linked Event07:53 – Supreme Court Declines Challenge to H-4 EAD Program (Spouses of H-1B Holders) 08:27 – No New AAO Decisions 09:19 – USCIS Policy Manual Update: Marriage Cases 12:52 – H-1B Site Update 13:27 – 3rd Cir.: No Duty to Warn Clients of Criminal Liability 14:07 – Outro 15:00 – Closing Show Notes: New Parole Fee 9th Circ. Flouting 'Imperial Judiciary' Warning, Judges Assert Ninth Circuit rejects government's latest attempt to overturn the preliminary injunction (PI) keeping legal representation for unaccompanied children in place! U.S. revokes visas for 6 foreigners over Charlie Kirk-related speech The Supreme Court just declined to hear the challenge to the H-4 EAD program, thereby letting stand the D.C. Circuit's ruling that protects work authorization for certain spouses of H-1B visa holders USCIS policy manual update on Marriage Reminder about foreign divorces USCIS H-1B website updated with $100k fee info 3rd Circ. Says No Duty To Inform Criminal Clients Of Liability Spotify | iTunes | YouTube Music | YouTube Follow eimmigration by Cerenade: Facebook | Instagram | LinkedIn Start your Business Immigration Practice! (US LAWYERS ONLY - SCREENING REQUIRED): E-2 Course EB-1A Course Get the Toolbox Magazine! Join our community (Lawyers Only) Get Started in Immigration Law! The Marriage/Family-Based Green Card course is for you Our Website: ImmigrationLawyersToolbox.com Not legal advice. Consult with an Attorney. Attorney Advertisement. #podcaster #Lawyer #ImmigrationLawyer #Interview #Immigration #ImmigrationAttorney #USImmigration #ImmigrationLaw #ImmigrationLawyersToolbox
Ramos-Ramos v. Bondi, Nos. 23-9567, 24-9524 (10th Cir. Oct. 15, 2025)clear error standard of review; no need for BIA remand; circuit court granting asylum; unable or unwilling to protect; police failure to solve crime; police ignoring reporting; single mothers; nexus; relocation; fear of gangs; family based particular social group; Honduras Pastor-Hernandez v. Bondi, No. 24-3104 (6th Cir. Oct. 17, 2025)motion to reopen to apply for voluntary departure; affidavit swearing that passport application is pending; conclusory affidavit; prima facie case to relief Ani v. Bondi, No. 24-2339 (9th Cir. Oct. 16, 2025)adverse credibility; Alam; marriage fraud; denying asylum based on fraud to obtain different immigration benefitsSponsors and friends of the podcast!Kurzban Kurzban Tetzeli and Pratt P.A.Immigration, serious injury, and business lawyers serving clients in Florida, California, and all over the world for over 40 years. Eimmigration "Simplifies immigration casework. Legal professionals use it to advance cases faster, delight clients, and grow their practices."Homepage!Demo Link!Questions to ask! Stafi"Remote staffing solutions for businesses of all sizes"Promo Code: STAFI2025Click me! Gonzales & Gonzales Immigration BondsP: (833) 409-9200immigrationbond.com Want to become a patron?Click here to check out our Patreon Page! CONTACT INFORMATIONEmail: kgregg@kktplaw.comFacebook: @immigrationreviewInstagram: @immigrationreviewTwitter: @immreview About your hostCase notesRecent criminal-immigration article (p.18)Featured in San Diego VoyagerDISCLAIMER & CREDITSSee Eps. 1-200Support the show