New BIA Decision Permits Immigration Courts to Review Police Reports for Domestic Violence Determinations

In applying modified categorical approach to assess conviction, it is proper to consider police reports’ contents as part of conviction record if incorporated into plea or admitted by alien in criminal proceedings. Matter of Milian-Dubon, 25 I&N Dec. 197 (BIA 2010).

Here is the full BIA decision.


Matter of Millian -