The Legal Aid Society filed a coalitional amicus brief to explain to the Second Circuit how the Board of Immigration Appeals’ refusal to adopt a clear definition of “sexual abuse of a minor” when undertaking the categorical approach has harmed our clients. Courts employ the “categorical approach” to determine whether state convictions carry federal immigration consequences. The Board’s expansive, standardless approach to sexual abuse of a minor fails to provide defendants fair notice of what actions fall within the statute’s scope, and undermines—rather than supports—efficiency, fairness, and predictability in criminal and immigration proceedings. As a result, a teenaged noncitizen may be deemed an “aggravated felon,” and may be banished from the United States based on conduct as minimal as consensually kissing a younger teenager—a result that Congress could not plausibly have intended.