Bad news today for Ninth Circuit crimmigration gurus (like myself).  The Ninth Circuit has laid to rest any question as to whether Cal. Penal Code 273.5 (a common domestic violence statute that criminalizes assaults on cohabitants - individuals not typically conceived of as part of a domestic violence scheme) categorically matches the definition of a crime of domestic violence (it does).  Though I disagree with the court's determination that cohabitants are the substantial equivalent of a spouse (California state law clearly permits a person to have multiple cohabitants at once), the precedential case makes Cal. Penal Code 273.5 a very dangerous conviction for any non-citizen.  We will have to eagerly await to see if the court grants a petition for rehearing. 

The full text of Marquez Carrillo v. Holder can be found here: