§ 22.19 B. Analysis
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DOMESTIC VIOLENCE " VIOLATION OF PROTECTIVE ORDER " SIMILAR TO CIRCUMSTANCE SPECIFIC ANALYSIS
Matter of Obshatko, 27 I&N Dec. 173 (BIA 2017) (in considering whether a violation of a domestic violence protection order renders a noncitizen deportable, under INA 237(a)(2)(E)(ii), an IJ should consider the probative and reliable evidence regarding what a state court has determined about the violation), clarifying Matter of Strydom, 25 I&N Dec. 507 (BIA 2011). NOTE: While the court stated that neither the categorical, nor the circumstance-specific approaches were applicable to this ground, the board stated that any reliable evidence could be submitted. The Board clarified that when it previously applied the categorical approach to INA 237(a)(2)(E)(ii), it did not actually hold that the categorical approach should be applied to the TRO ground, it just did it. Thus, the BIA was completely free to change its prior rule, because it did not really mean to establish that as the rule.