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BIA on Divisibility, Elements, Means: Matter of Dikhtyar, 28 I&N Dec. 214 (BIA 2021)

January 22, 2021 (1 min read)

Matter of Dikhtyar, 28 I&N Dec. 214 (BIA 2021) - Section 58-37-8(2)(a)(i) of the Utah Code, which criminalizes possession or use of a controlled substance, is divisible with respect to the identity of the specific “controlled substance” involved in a violation of that statute.