The following excerpt is from United States v. Yijun Zhou, 838 F.3d 1007 (9th Cir. 2016):
I concur in full in the majority's opinion. I write separately to question the validity of our case law with respect to the standard of review applicable to arguments raised for the first time on appeal by criminal defendants.
Henderson v. United States , U.S. , 133 S.Ct. 1121, 1124, 185 L.Ed.2d 85 (2013)
[838 F.3d 1015]
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