The Board didn’t stray too far from the norm in
Matter of M-W-, 25 I&N Dec. 748 (BIA 2012), the only precedent decision helping to define which crimes amount to “murder” under INA 101(a)(43).
In invoking the Taylor methodology—examining, inter alia, common-law and State law to identify the “uniform, categoricaldefinition[]” of an offense—our touchstone is the definition of the crime of “murder” that Congress had in mind when it added that offense to the Actas an aggravated felony in 1988.5 Taylor v. United States, 495 U.S. at 581-82,587-77, 590.
The Board concluded that “murder” does not require an “intent to kill” and that an involuntary killing as the result of drunk driving qualifies as “murder” and thus rendered the respondent removable.