The Third Circuit has deferred to the agency’s determination in Matter of Wong that New Jersey disorderly persons offenses are convictions for immigration purposes. However, the court remanded for further analysis of whether the proposed social group of “Honduran women in a domestic relationship where the male believes that women are to live under male domination” is cognizable for asylum purposes.

The full text of Avila v. Attorney General can be found here:

https://www2.ca3.uscourts.gov/opinarch/221374p.pdf

Comment