Sixth Circuit defers to Matter of Y-L-

Luambano v. Holder, No. 13-3881 (6th Cir. Apr. 30, 2014) (unpublished)

In this decision, the court deferred to the AG's decision in Matter of Y-L-, 23 I&N Dec. 270 (AG 2002), which found that drug trafficking convictions are presumptively particularly serious so as to bar an applicant from withholding of removal.

It is unclear why the petitioner conceded that his conviction for delivery of marijuana is an aggravated felony drug trafficking offense, when he could have argued otherwise.