The Supreme Court has affirmed the use of the ordinary meaning of the language of a statute defining a ground of deportation. The domestic violence deportation ground requires that the noncitizen must have been "convicted of a crime of domestic violence," INA 237(a)(2)(E)(i), 8 U.S.C. 1227(a)(2)(E)(i)(emphasis supplied), before this ground of deportation is triggered. This language requires that the conviction itself must be a crime of (a) domestic and (b) violence, since it requires that the respondent be "convicted" of a crime of "domestic violence." Therefore, the statute requires that both the domestic element (the specified relationship) and the crime of violence (under 18 U.S.C. 16) must be part of the conviction itself. The cases that suggest to the contrary ignore this plain statutory language, and their discussions are mostly dictum. See Singh v. Ashcroft, 383 F.3d 144 (3d Cir. 2004); Flores v. Ashcroft, 350 F.3d 666, 669 (7th Cir. 2003); Emile v. INS, 244 F.3d 183 (1st Cir. 2001); Sutherland v. Reno, 228 F.3d 171, 176-78 (2d Cir. 2000). The correct rule, firmly grounded on the language of the statute, is that the domestic relationship must be contained in the essential elements of the statute of conviction, as framed by the state legislature or Congress, before a conviction under that statute can constitute a "crime of domestic violence" so as to trigger this ground of deportation. Tokatly v. Ashcroft, 371 F.3d 613, 622-23 (9th Cir. 2004). Thanks to Lory Rosenberg for this point.