In a case decided today, Sessions v. Dimaya, 584 U.S.____ (2018), 18 USC §16(b) has been struck down by the U.S. Supreme Court as void for vagueness.  Specifically, the provision stated that “a ‘crime of violence’ [is] ‘any offense that is a felony and that, by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense.’”  The Court likened the situation to a previous case, Johnson v. United States, 576 U.S. 133 (2015), in which the Armed Career Criminal Act’s residuary clause was struck down because it “created ‘grave uncertainty about how to estimate the risk posed by a crime.”  Specifically, it required the judge to make an assessment based upon a possible situation “but provided no guidance” to what a crime’s “ordinary case was” as well as providing that same imprecise reasoning with no guidance to making a risk assessment.  The Court also dismissed the notion that the a less demanding vagueness doctrine should apply, quoting its own precedent in Jordan v. De George, 341 U.S. 223 (1951), “’’in view of the grave nature of deportation,’ the most exacting vagueness standard must apply.”  The Court notes that removal proceedings have become increasingly connected to criminal matters as convictions have become more significant grounds in placement into removal proceedings and qualifying for relief.  This changes the viewpoint of aggravated felonies in that there must be clarity about what conduct leads to a finding of an aggravated felony and not open-ended speculation.  Subsequent litigation on these issues will be of interest as this new standard is applied and will change the analysis and argument that must be brought to relevant cases.