Ochieng v. Mukasey, 520 F.3d 1110, 1114-15 (10th Cir. 2008) (the definition of "child abuse" under INA 237(a)(2)(E)(i), 8 U.S.C. 1227(a)(2)(E)(i), set forth in dictum in a precedent BIA decision, was entitled to deference because it was based on a permissible construction of the statute), applying Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 842-43 (1984); accord Loeza-Dominguez v. Gonzales, 428 F.3d 1156 (8th Cir. 2005); but cf. Velasquez-Herrera v. Gonzales, 466 F.3d 781, 783 (9th Cir. 2006) (BIA never formally defined the concept of "child abuse" in a precedent decision, except in dictum, and the Immigration Judge's opinion, which equated the concept of "child abuse" with any assault committed against a child, embodied a broader understanding of the concept than the BIA had articulated).