(C)  Juvenile Court Orders.  This deportation ground may apply to juveniles, as well as adults, since it does not depend on the existence of a criminal conviction, and it is likely (though not certain) that a juvenile court would be considered a “civil or criminal court” for this purpose.  It is therefore important to avoid a juvenile-court finding that the minor violated a domestic violence TRO.  Immigration counsel can argue that authority holding juvenile court findings do not constitute convictions[167] would preclude deportability based on this type of finding as well.  See § 12.21, supra.

[167] Matter of Ramirez-Rivero, 18 I. & N. Dec. 135 (BIA 1981); Matter of CM, 5 I. & N. Dec. 327 (BIA 1953) (juvenile finding of commission of crime involving moral turpitude does not constitute a “conviction” or trigger inadmissibility).

BIA

DOMESTIC VIOLENCE " VIOLATION OF PROTECTION ORDER
Matter of Strydom, 25 I. & N. Dec. 507 (BIA May 24, 2011) (Kansas conviction for attempting to make a phone call to his wifes home in violation of the no-contact provision of a temporary protection order, in violation of Kan. Stats. 21-3843(a)(1), triggers deportation under INA 237(a)(2)(E)(ii)), following Szalai v. Holder, 572 F.3d 975, 982 (9th Cir. 2009) (petitioners violation of the 100 yard stay away provision in Oregon Family Abuse Prevention Act restraining order triggers deportation under INA 237(a)(2)(E)(ii)); Alanis-Alvarado v. Holder, 558 F.3d 833, 839-40 (9th Cir. 2009) (injunction against telephoning a domestic partner in the context of a domestic violence protective order involves protection against violence, threats, or harassment, even if it is possible that the [offenders] violative conduct did not independently constitute violence, threats, or harassment[,] since INA 237(a)(2)(E)(ii) only requires a violation of the portion of a protection order that involves protection against credible threats of such conduct.) (internal quotation marks omitted).

Tenth Circuit

DOMESTIC VIOLENCE " NO CONTACT ORDER
Cespedes v. Lynch, 805 F.3d 1274 (10th Cir. Nov. 19, 2015) (any violation of a protection order will trigger 8 U.S.C. 1227(a)(2)(E)(ii), INA 237(a)(2)(E)(ii)), agreeing with Matter of Strydom, 25 I. & N. Dec. 507, 510 (2011).

Other

DOMESTIC VIOLENCE"DEPORTATION GROUND"PROTECTION ORDER VIOLATION"DEFENSES
Congress limited the deportation ground triggered by a court finding of a violation of a domestic violation protective order, under INA 237(a)(2)(E)(ii), 8 U.S.C. 1227(a)(2)(E)(ii), to protective orders against "credible threats of violence, repeated harassment [etc.]," as opposed to just protective orders against "threats of violence and harassment. (Emphasis added.) This certainly implies that the person must have been found in violation of the portion of a protective order that protects against credible threats, and does not apply unless the protection order specifically does so. Thanks to David Antn Armendriz.