However, each of these cases resulted in actual physical harm, not threatened harm.The BIA then compared the requirement of conduct under the statute at hand particularly to its decision in Matter of Leal, 26 I&N Dec. 20 (BIA 2012), aff’d, 771 F.3d 1140 (9th Cir. 2014). In Matter of Leal, the BIA applied the categorical approach under Silva-Trevino to section 13-1201(A) of the Arizona Revised Statutes, which punishes “recklessly endangering another person with a substantial risk of imminent death” (emphasis added).