Jeff Soun Howard A/K/A Mohamed Kandiel v. Immigration and Naturalization Service

This circuit reviews for the first time the issue whether the finding of alienage in a prior criminal case collaterally estops the alien from relitigating the issue of his citizenship in a later administrative proceeding. Jeff Soun Howard a/k/a Mohamed Ibrahim Kandiel (Kandiel) petitions for review of an order of the Board of Immigration Appeals (BIA) upholding an order of deportation entered by the immigration judge. Because we find that Kandiel is estopped from challenging a finding of al-ienage in his earlier criminal conviction and that the other grounds which he raises for review lack…