
EOIR BIA Decision
The Board of Immigration Appeals has issued a decision in Matter of FRIAS ULLOA, 29 I&N Dec. 259 (BIA 2025).
Section 2C:35-5(b)(4) of the New Jersey Statutes Annotated is divisible by controlled substance, and applying the modified categorical approach, the respondent’s record of conviction identifies the relevant substance as fentanyl, a federally controlled substance. Matter of Laguerre, 28 I&N Dec. 437 (BIA 2022), followed.