context: No consensus exists among our sister Courts of Appeals as to what quantum of deference, if any, should be accorded to these opinions. After Mead, several Courts of Appeals affirmatively rejected application of Chevron deference to unpublished BIA decisions.
citation_a.signal: but see
citation_a.identifier: 469 F.3d 683, 689-690
citation_a.parenthetical: according Chevron deference to BIA's streamlined adoption of IJ decision
citation_a.sentence: But see Gutnik v. Gonzales, 469 F.3d 683, 689-690 (7th Cir.2006) (according Chevron deference to BIA’s streamlined adoption of IJ decision).
citation_b.signal: see
citation_b.identifier: 473 F.3d 55, 57-58
citation_b.parenthetical: holding that an unpublished BIA decision that does not rely on precedent for its definition of a contested term does not receive Chevron deference, because it is not "promulgated under [the agency's] authority to make rules carrying the force of law"
citation_b.sentence: See Quinchia v. Att’y Gen., 552 F.3d 1255, 1258 (11th Cir.2008) (stating that an unpublished BIA decision that does not rely on BIA or Court of Appeals precedent does not receive Chevron deference); Rotimi v. Gonzales, 473 F.3d 55, 57-58 (2d Cir.2007) (holding that an unpublished BIA decision that does not rely on precedent for its definition of a contested term does not receive Chevron deference, because it is not “promulgated under [the agency’s] authority to make rules carrying the force of law”) (internal quotation marks omitted); Garcia-Quintero v. Gonzales, 455 F.3d 1006, 1012-14 (9th Cir.2006) (opining that an unpublished BIA decision does not have the force of law and therefore does not receive Chevron deference).