The Second Circuit determined that the REAL ID Act, by its terms, applies only to applications for relief.  Thus, the Board of Immigration Appeals erred by applying the standards of the Act to a contested removability determination.  This is a great decision for attorneys to reference when litigation so-called Quilantan cases, where there is an assertion that the non-citizen was admitted to the United States, but there may not be any documentary evidence to support the assertion.  

The full text of Ahmed v. Lynch can be found here: