The Ninth Circuit held that California's voluntary manslaughter statute, which can be violated through reckless conduct, does not qualify as a crime of violence, which requires the intentional use of force.  In addition, the court held that a claim for protection under the Convention Against Torture must be evaluated "in terms of the aggregate risk of torture from all sources, and not as separate, divisible CAT claims."  Thus, the agency erred by failing to consider the aggregate risk of torture posed to the petitioner by both his status as a criminal deportee and his family affiliation.  

The full text of Quijada-Aguilar v. Lynch can be found here: