The Board of Immigration Appeals has determined that the crime of domestic violence deportability ground is subject to a circumstance specific analysis. Specifically, the question as to whether a conviction meets the definition of a crime of violence will be analyzed under the categorical approach, while the domestic nature of the relationship will be analyzed under the circumstance specific approach. This approach allows adjudicators to consult police reports and other reliable evidence outside of the record of conviction to determine if a domestic relationship existed between the defendant and the victim.
The full text of Matter of H. Estrada can be found here: https://www.justice.gov/eoir/file/862581/download