OBSHATKO

Citations

• 27 I. & N. Dec. 173

Syllabus

OBSHATKO, 27 I&N Dec. 173 (BIA 2017) 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 has determined about the alien's violation. Matter of Strydom 25 I&N Dec. 507 (BIA 2011), clarified.