Henry Javier Mendoza Osorio is a native of Ecuador and a United States lawful permanent resident. Matter of Mendoza Osorio, 26 I&N Dec. 703 (BIA 2016). Mr. Mendoza Osorio was convicted of endangering the welfare of a child under § 260.10(1) of the New York Penal Law.

The Matter of Cavillo-Garcia, 26 I&N Dec. 697 (BIA 2015) [see article]Decided: December 9, 2015The Board held that a term of confinement in a substance abuse treatment facility imposed as a condition of probation (under a Texas state statute) constitutes a “term of confinement” under INA 101(a)(48)(B) for purpose of determining if an offense is an immigration aggravated felony [see article] for a crime of violence under INA 101(a)(43)(F) [see section].The Matter of Mendoza-Osorio, 26 I&N Dec. 703 (BIA 2016) [see article]Decided: February 9, 2016The offense of endangering the welfare of a child under a New York state statute, which requires knowingly acting in a matter likely to be injurious to the physical, mental, or moral welfare of a child, is categorically [see article] an offense covered by INA 237(a)(2)(E)(i) for a “crime of child abuse, child neglect, or child abandonment.”The Matter of Guzman-Polanco, 26 I&N Dec. 713 (BIA 2016) [see article]Decided: February 24, 2016The Board held that for a state offense to qualify as a crime of violence under 18 U.S.C. 16, the state statute must require as an element the use, attempted use, or threatened use of physical force.