The Eighth Circuit has determined that an Iowa statute which criminalizes possessing a forged instrument with the intent to perpetuate a fraud or with the knowledge his possession was facilitating a fraud, qualifies as a forgery-related aggravated felony. The court also determined that a reinstatement order is not final if a petitioner requests a reasonable fear interview. The order became final once the Immigration Judge affirmed the Asylum Officer’s negative reasonable fear determination. Finally, the court acknowledged that the Department of Homeland Security violated the petitioner’s due process rights by issuing a Final Administrative Removal Order (FARO) before the deadline for him to respond to the Notice to Intent to Issue the FARO had passed, but found that he could not establish any prejudice from this violation.

The full text of Cardoza Salazar v Barr can be found here: