Gertsenshteyn v. Mukasey, 544 F.3d 137 (2d Cir. Sept. 25, 2008) ("When the BIA has adopted the IJ's reasoning and offered additional commentary, we review the decision of the IJ as supplemented by the BIA. Wala, 511 F.3d at 105. Additionally, when our jurisdiction depends on the definition of a phrase used in the INA, and "when the intent of Congress is unclear and the agency's interpretation is reasonable," we accord the BIA's determination the deference mandated by the Supreme Court's decision in Chevron. Mugalli, 258 F.3d at 55 (internal quotation marks omitted). But when, in the course of interpreting the INA, the BIA has interpreted state or federal criminal laws, we review its decision de novo. Id.").