Matter of Sangchul Lee, 2013 WL 3899749, A200-298-115 (BIA July 5, 2013) (unpublished).
The BIA held that aggravated assault, MCL 750.81a is not categorically a CIMT. It specifically does not require the use of a weapon and it requires an intent less than an intent to commit murder or great bodily harm less than murder.
The BIA remanded for a modified categorical approach.
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