Andrade v. Gonzales, __ F.3d __ (5th Cir. Aug. 1, 2006) (Massachusetts conviction of battery, in violation of Mass. Gen. Laws Ch. 265, 13A, although divisible, is found in this case to be an aggravated felony crime of violence under INA 101(a)(43)(F), as falling under 18 U.S.C. 16(a), where the conviction "also concerned a violation of a domestic abuse protective order.")
http://caselaw.lp.findlaw.com/data2/circs/5th/0430247cv0p.pdf



The court apparently assumed it would be impossible to violate a protection order by an unwanted touching, which is sufficient to constitute a violation of the criminal statute. The court also failed to mention whether the record of conviction contained any information regarding the domestic abuse. The noncitizen in this case had 21 total convictions, and had been involved in litigating pro se for a number of years at all court levels.