U.S. Attorney General Eric Holder reversed a January policy change implemented by former Attorney General Michael Mukasey, according to which noncitizens had no constitutional right to effective counsel in removal (deportation) proceedings. The Mukasey ruling, in turn, had reversed a 15-year-old precedent established in Matter if Lozada, which recognized a 5th amendment due process right to a new hearing in the case of ineffective assistance of counsel. Holder ordered the Executive Office for Immigration Review to "initiate rulemaking procedures ... to evaluate the Lozada framework and to determine what modifications should be proposed for public consideration." To read the Holder ruling click here. For a New York Times article on the Holder reversal click here.