Matter of Gruenangerl

1 Analyses of this admin-law by attorneys

  1. BIA: Interpret “relating to” language in firearms aggravated felony provision broadly

    University of Denver Sturm College of LawDecember 10, 2013

    Moreover, “[t]he Board and courts of appeals ‘have consistently ruled that the phrase ‘relating to’ has an expansive meaning.’” Matter of Oppedisano, 26 I&N Dec. at 204 (quoting Matter of Gruenangerl, 25 I&N Dec. 351 (BIA 2010)). When Congress wants to use a parenthetical as a means of limiting the application of a statutory provision, the Board added, it knows how to accomplish that—by using “clear and distinct” language such as “except,” “if,” and “but not including.”