The Board of Immigration Appeals (Board) issued its fourth decision in Matter of Chairez-Castrejon, reaffirming the use of the categorical approach in immigration proceedings, and the applicability of the Supreme Court's definition of a divisible statute in Mathis v. United States.  The Board also noted that it is only appropriate to "peek" at a record of conviction to ascertain the divisibility of a statute if state case law is not clear in identifying the elements of the statute.

The full text of Matter of Chairez-Castrejon can be found here: