The Board of Immigration Appeals (Board) issued its fourth decision in Matter of Chairez-Castrejon, reaffirming the use of the categorical approach in immigration proceedings, and the applicability of the Supreme Court's definition of a divisible statute in Mathis v. United States. The Board also noted that it is only appropriate to "peek" at a record of conviction to ascertain the divisibility of a statute if state case law is not clear in identifying the elements of the statute.
The full text of Matter of Chairez-Castrejon can be found here: https://www.justice.gov/eoir/page/file/959656/download