Florez v. Holder, 779 F.3d 207 (2d Cir. Mar. 4, 2015) (Ibarra also violates the rule that deference is owed to reasonable agency interpretations even if a court has previously construed that very statutory provision differently. See Nat'l Cable & Telecomms. Ass'n v. Brand X Internet Servs., 545 U.S. 967, 982"83, 125 S.Ct. 2688, 162 L.Ed.2d 820 (2005). To illustrate: even if the U.S. Supreme Court had previously interpreted this very statutory provision to apply only to child abuse statutes for which harm was an element, that (hypothetical) precedent would not have foreclosed the BIA's interpretation here (unless, of course, the Court read the statute to be unambiguous). See id.).