Advisory About the Immigration Consequences of California Methamphetamine Convictions: Lorenzo v. Sessions

In August 2018, the Ninth Circuit published an opinion holding that methamphetamine as defined under California law is not a controlled substance for federal immigration purposes. In January 2019, however, the court withdrew the published opinion, and issued a non-published opinion that came to the same conclusion. See Lorenzo v. Sessions , 902 F.3d 930 (9th Cir. 2018), withdrawn by Lorenzo v. Whitaker , 913 F.3d 930 (9th Cir. 2019), and unpublished decision at Lorenzo v. Whitaker , 752 F. App'x