from the common law. At common law, courts were directed “to follow decisions made in an earlier proceeding.” Bethea v. Levi Strauss & Co., 916 F.2d 453, 457 (8th Cir. 1990) (citations omitted). The Supreme Court has similarly understood the doctrine. See Arizona, 460 U.S. at 618, 103 S.Ct. 1382 (“[Wjhen a court decides upon a rule of law, that decision should continue to govern the same issues in subsequent stages in the same case.” (footnote and citation omitted)). On remand from the BIA, the IJ reconsidered and reversed its prior decision that Estrada’s Arkansas assault conviction is not a CIMT. As the BIA noted, nothing in its order reopening and remanding the action precluded the IJ from reconsidering the CIMT issue on remand. See In re Patel, 16 I. & N. Dec. 600, 601 (BIA 1978) (<HOLDING>). The BIA remanded the action to the IJ “for
holding that rule 11 sanctions are not appropriate when a motion is filed in part for a legitimate purpose even when the motion includes certain evidence which is assertedly presented for an improper purpose holding that a remand unless qualified or limited for a specific purpose is effective for the stated purpose and for consideration of any and all matters that the ij deems appropriate recognizing district courts power to admit evidence for a limited purpose holding that unless remand from the bia is qualified or limited to a specific purpose an ij may consider any and all matters he  deems appropriate in the exercise of his administrative discretion or which are brought to his attention in compliance with the appropriate regulations holding that a defendant is in custody and miranda applies even when the purpose of defendants detention is unrelated to the purpose of the interrogation