The Board of Immigration Appeals (BIA) has adopted a new definition of an aggravated felony related to perjury. The BIA withdrew from its prior decision in Matter of Martinez-Recinos. Instead, the BIA surveyed state definitions of perjury and determined that the generic definition of an aggravated felony related to perjury requires that "an offender make a material false statement knowingly or willfully while under oath or affirmation where an oath is authorized or required by law." The BIA then concluded that perjury in violation of section 118(a) of the California Penal Code matches this definition.
The full text of Matter of Alvarado can be found here: