NEW RULES REGARDING DETERMINING DIVISIBILITYOn September 28, 2016, the Board of Immigration Appeals (BIA) issued an important precedent decision titled the Matter of Chairez, 26 I&N Dec. 819 (BIA 2016) [PDF version]. The Board set forth new rules for determining when a criminal statute may be considered “divisible” for purposes of applying the modified categorical approach that are in accord with the Supreme Court decisions in Descamps v. United States, 133 S.Ct. 2276 [PDF version] and Mathis v. United States, 133 S.Ct. 2243 (2016) [PDF version].