Ikharo v. Holder, No. 08-4139 (6th Cir. Feb. 16, 2012) (unpublished)
Previously in this case, the Sixth Circuit followed the BIA's corresponding ground rule in 212(c) cases. Following Judulang and a remand in this case from the Supreme Court, the Sixth Circuit remanded to the BIA to come up with a new framework for 212(c) eligibility determinations.