Perez v. Holder
October 27, 2009
**IAC**
The BIA erred in finding that Perez presented no evidence that his counsel was inadequate. Also, while a showing of prejudice was required, the BIA did not actually decide that there was no prejudice, but only that counsel’s “tactical decisions” did not cause prejudice.
http://www.ca9.uscourts.gov/datastore/memoranda/2009/10/27/05-74042.pdf
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