On October 30, 2015, the Attorney General ordered rehearing of the Board of Immigration Appeals’ decision in In the Matter of Chiarez-Casterjoin.  In that decision, the Board of Immigration Appeals handed down a decision on the categorical rule which noted that a statute is not divisible under Descamps if there are two ways to violate the same same statute and that the easier way to convict the Defendant does not require the jury to find that the Defendant committed the crime involving moral turpitude.  In the Matter of Chairez-Casterjon,  26 I&N Dec. 686 (A.G. 2015).  A decision is expected before the end of the year.