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

Written by Alexander J. Segal on

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.”