The 9th Circuit Court of Appeals has held that a conviction for carrying a concealed weapon under California Penal Code §12025(a) is categorically a removable firearms offense under INA §237(a)(2)(C). See Gil v. Holder, 6/22/11
The 10th Circuit has made a ruling relating to the scope of the Supreme Court decision, Padilla v. Kentucky. The 10th found that the government is not required to prove in immigration proceedings that an alien received constitutionally adequate advice about the consequences of his criminal plea for the plea to be valid for immigration purposes. See Waugh v. Holder, 6/22/11.