Ng v. Attorney General, ___ F.3d ___ (3d Cir. Feb. 7, 2006)(BIA interpretation of crime of violence definition contained in 18 U.S.C. 16 is not entitled to deference, since it lies outside the Immigration and Nationality Act and thus outside the BIA's special area of expertise), citing Singh v. Gonzales, ___ F.3d ___ (3d Cir. Jan. 3, 2006).
http://caselaw.lp.findlaw.com/data2/circs/3rd/044672p.pdf