The Fourth Circuit has adopted a "circumstance specific" approach to analyzing the crime of domestic violence deportability ground as opposed to the traditional "categorical approach" that is typically employed to evaluate the immigration consequences of a criminal conviction. This means that the statute of conviction need contain a domestic relationship for a conviction to sustain a charge of deportability. If evidence (i.e. documents from the criminal court) establish that the defendant and the victim had such a relationship, that will be sufficient to render the defendant deportable. Thus, non-citizens in the Fourth Circuit must now be considered that convictions for generic assault crimes, which contain no requirement of a domestic relationship to the victim, may still make them deportable or ineligible for certain forms of immigration relief, if the victim, was in fact, someone with whom they shared a domestic relationship.
The full text of Hernandez-Zavala v. Lynch can be found here: http://www.ca4.uscourts.gov/Opinions/Published/141878.P.pdf