Wednesday, June 30, 2021 - 01:00
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Is It the End of the World as We Know It or Do We Feel Fine? How Palomar-Santiago Did (and Didn't) Change Collateral Challenges to Prior Removal Orders Under § 1326(d).

Time: 1:00 PM - 2:15 (EDT)

In Palomar-Santiago, the Supreme Court addressed collateral challenges to underlying removal orders in illegal reentry prosecutions for the first time since Mendoza-Lopez, the watershed decision it issued 34 years ago. But did Palomar-Santiago gut our precedent, open up new arguments, or some of both? This webinar will discuss the procedural history and holding of Palomar-Santiago, the negative effects it could have in some circuits, and creative strategies for using it to expand our litigation options in other circuits.  


Joseph Camden is an Assistant Federal Public Defender in the Richmond office of the Eastern District of Virginia.  Before coming to Richmond in 2017, he spent seven years as a trial attorney at Federal Defenders of San Diego, Inc., where he focused on litigating illegal reentry cases and categorical approach issues.  And before that, he spent a couple years teaching English in Siberia.  He is available for advice or to share briefing on categorical approach issues any time.

Kara Hartzler is an appellate attorney at the Federal Defenders of San Diego, Inc.  Prior to joining the Federal Defenders, she served as the Legal Director and Criminal Immigration Consultant at the Florence Immigrant and Refugee Rights Project in Arizona, where she specialized in the immigration consequences of criminal convictions.  She has authored numerous books, articles, and resources for defense attorneys, including Surviving Padilla:  A Defender’s Guide to Advising Noncitizens on the Immigration Consequences of Criminal Convictions.  Kara also served as an adjunct professor at the University of Arizona College of Law and testified in front of the U.S. House of Representatives Subcommittee on Immigration on the detention and deportation of citizens and other due process violations in the immigration system.  She is the recipient of the 2018 E. Stanley Conant Award, the 2017 Outstanding Assistant Federal Defender award, the 2013 David Carliner Public Interest Award, the 2013 Randy Tunac Courage in Immigration Award, and the 2010 Robert J. Hooker Award for service to the defender community.

The Training Division is not applying for CLE for this webinar.