United States Fourth Circuit

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Hernandez-Zavala v. Lynch, 14-1878

In an immigration action, the Board of Immigration Appeal's decision that petitioner had committed a crime of domestic violence making him ineligible for cancellation of removal is affirmed where a state law conviction for a crime of violence, that does not have require a domestic relationship as an element of the offense, can constitute a crime of violence under 8 U.S.C. section 1227(a)(2)(E)(i) when the underlying facts involve a domestic relationship.

Appellate Information

  • Decided
  • Published 2015/11/20




  • United States Fourth Circuit