The court closed by noting that, after oral arguments were heard, the Board did overrule Sanchez. Margulis, No. 12-3611, slip op. at 7-8 (discussing Matter of Rivas, 26 I&N Dec. 130 (BIA 2013)). Because that decision was based on the Board’s review of congressional intent, thought, it’s ripe for review and unclear whether this applies retroactively.