No. 23-1069 ___________________________

Simon Gavino Quito-Guachichulca

Petitioner

v.

Merrick B. Garland, Attorney General of the United States

Respondent

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National Immigration Project of the National Lawyers Guild

Amicus on Behalf of Petitioner ____________

Petition for Review of an Order of the Board of Immigration Appeals ____________

Submitted: February 15, 2024 Filed: December 9, 2024 ____________ Before BENTON, GRASZ, and STRAS, Circuit Judges. ____________ STRAS, Circuit Judge. The question in this case is whether Minnesota’s crime of third-degree criminal sexual conduct falls within the federal definition of “rape.” The