The Seventh Circuit has denied a petition for review filed by a Mexican woman found ineligible for cancellation of removal based on a Wisconsin misdemeanor conviction for neglecting a child, holding that the offense is a categorical match to the federal removability ground for a crime of child abuse, neglect, or abandonment.
Joining the Fourth, Fifth, and Ninth Circuits, the Court held that the federal ground should be read as a single, unified category requiring only a culpable mental state of at least criminal negligence and an act or omission creating a reasonable probability of harm to a child. Because Wisconsin's statute requires proof of intentional conduct, a higher mens rea than the federal floor, and does not require that the child actually suffer any injury, the Court held the state offense sweeps no more broadly than the federal ground and denied the petition.
The full text of Reynoso-Salgado v. Blanche can be found here: https://media.ca7.uscourts.gov/cgi-bin/OpinionsWeb/processWebInputExternal.pl?Submit=Display&Path=Y2026/D09-01/C:23-2628:J:Jackson-Akiwumi:aut:T:fnOp:N:3601340:S:0