BIA Issues Clarification in the Matter of Guzman-Polanco, 26 I&N Dec. 806 (BIA 2016)

Alexander J. Segal's picture

On Sep. 9, 2016, the Board clarified its decision from earlier in the year in the Matter of Guzman-Polanco, 26 I&N Dec. 713 (BIA 2016). The Board explained that it will follow controlling circuit court law regarding whether “conduct such as the threatened use of poison to injure a person” may be sufficient to constitute a “crime of violence.”

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