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

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.”