The Matter of Guzman-Polanco, 26 I&N Dec. 713 (BIA 2016) [see article]Decided: February 24, 2016The Board held that for a state offense to qualify as a crime of violence under 18 U.S.C. 16, the state statute must require as an element the use, attempted use, or threatened use of physical force. The Board then held that a Puerto Rico statute for aggravated battery was not categorically a crime of violence under 18 U.S.C. 16 because it could be committed by means that do not involve the use of violent physical force.The Matter of Villalobos, 26 I&N Dec. 719 (BIA 2016)Decided: March 10, 2016The Board held that Immigration Judges and the BIA have jurisdiction to determine whether an alien was eligible for a previous adjustment of status under INA 245A(b) for purposes of assessing an alien’s removability and eligibility for relief from removal. It also held that an alien seeking to apply permanent residence through the legalization provisions of section INA 245A must establish admissibility at the time of the initial application for temporary residency and again when applying for adjustment of status to permanent resident status under INA 245A(b)(1).