In a significant precedent decision, the Board of Immigration Appeals has overruled Matter of K- (1957) and Matter of J- (1945), holding that an alien's admission to having possessed and used cocaine renders him inadmissible under INA § 212(a)(2)(A)(i)(II) even though he was never advised of the precise statutory definition or essential elements of the offense before admitting to the conduct.
The Board reasoned that the controlled substance inadmissibility ground requires only that the respondent voluntarily admit to conduct that constitutes the essential elements of the offense and receive a fair hearing — nothing in the statute's plain language requires that he first be instructed on the formal legal definition of the crime. Requiring that additional procedural step, the Board held, "exceeds what is required under the plain language of the statute," and the appeal was dismissed.
The full text of Matter of Tirso Mendez Maldonado can be found here: https://www.justice.gov/eoir/media/1462126/dl?inline