OBSHATKO
Board of Immigration Appeals
1Opinion of the Court
Cite as
27 I&N Dec. 173
(BIA 2017) Interim Decision #3909 Matter of Alex Pieniazek OBSHATKO, Respondent Decided November 17, 2017 U.S. Department of Justice Executive Office for Immigration Review Board of Immigration Appeals Whether a violation of a protection order renders an alien removable under section 237(a)(2)(E)(ii) of the Immigration and Nationality Act, 8 U.S.C. § 1227(a)(2)(E)(ii) (2012), is not governed by the categorical approach, even if a conviction underlies the charge; instead, an Immigration Judge should consider the probative and reliable evidence regarding what a State court…
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