On November 29, 2012, the Board of Immigration Appeals (BIA) found that a conviction for stalking under California Penal Code §646.9 qualifies as a “crime of stalking” as defined by INA §237 (a)(2)(E)(i), thus rendering the respondent removable. Matter of Sanchez-Lopez, 26 I. & N. Dec. 71 (BIA 2012).
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