Section 237(a)(2)(E)(ii) of the INA renders deportable any alien who at any time after admission is en‐joined under a protection order issued by a court and whom the court determines has engaged in conduct that violates the portion of a protection order that involves protection against credible threats of violence, repeated harassment, or bodily injury to the person or persons for whom the protection order was issued.  The Seventh Circuit has determined that because the statute references a criminal court's determination, an immigration court is not confined to categorical approach when determining if a non-citizen violated the portion of an order designed to protect against threats, harassment, and injury.

The full text of Garcia-Hernandez v. Boente can be found here: