In a published decision released last week, the BIA held that a term of imprisonment imposed after a probation violation is considered part of the penalty imposed for the original underlying conviction rather than a penalty imposed for a separate offense. Matter of Perez Ramirez, 25 I&N Dec. 203, 205 (BIA 2010) (Filppu, Cole, and Pauley). The BIA also held that California’s willful infliction of corporal injury on a spouse, Cal. Penal Code § 273.5(a), is a crime of violence type of aggravated felony.