vated felony provision found in INA 101(a)(43)(T) [see section], the categorical approach should be used to determine whether the offense was for failure to appear before a court, but the circumstance-specific approach should be used to determine if the underlying offense was under a court order to answer or dispose of a charge of felony for which a sentence of 2 years’ imprisonment or more may be imposed.The Matter of Gonzalez-Romo, 26 I&N Dec. 743 (BIA 2016) [see article]Decided: May 19, 2016The Board held that within the jurisdiction of the Ninth Circuit [1], a permanent resident who has a felony conviction for solicitation to possess marijuana for sale is inadmissible under INA 212(a)(2)(A)(i)(I) as an alien who committed a crime of moral turpitude even though INA 212(a)(2)(A)(i)(I) refers only to attempt and conspiracy to commit a crime of moral turpitude.Please see our related article on the immigration aggravated felony for trafficking in controlled substances [see article].The Matter of H. Estrada, 26 I&N Dec. 749 (BIA 2016) [see article]The Matter of H. Estrada dealt with two distinct issues, so we broke the case into three articles (an introduction and one article covering each of the issues).First, the Board held that when determining whether a conviction is for a crime of domestic violence under INA 237(a)(2)(E)(i), the circumstance-specific approach should be applied to determine the domestic nature of the offense [see article].