PUGIN v. GARLAND

Holding that Virginia accessory after the fact is categorically an offense “relating to obstruction of justice” and thus an aggravated felony because it requires specific intent. The Court determined that the agency's definition of "obstruction of justice" is entitled to Chevron deference because the INA is a civil statute and lenity does not apply, the phrase is ambiguous, and the agency's interpretation is reasonable. Judge Gregory dissented, determining that Chevron deference did not extend to the agency's interpretation of the statue because the phrase is unambiguous and alternatively, the agency's interpretation was unreasonable.

Date of Decision
Published