The Board of Immigration Appeals (Board) has determined that a conviction in California for mayhem is categorically under a crime of violence under 18 USC 16(a).  The Board noted that that the statute required the infliction of great bodily injury, such as the poking out of an eye, and that such injury necessarily required the use of violent force.

The full text of Matter of Kim can be found here: 

https://www.justice.gov/eoir/page/file/933996/download

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