In a precedential decision, the BIA held that New York’s attempted arson offense falls within the arson category of aggravated felony. Matter of Bautista, 25 I&N Dec. 616 (BIA 2011) (Grant, Malphrus, and Mullane, Board Members).Board Member Mullane wrote the panel’s opinion.This case involved a LPR who was convicted of attempted arson in violation of New York Penal Code §§ 110 and 150.10.