Fourth Circuit: Andrew Shaw v. Jefferson Sessions III

Immigration authority can look through convictions for inchoate offenses to determine if the underlying charged conduct bars withholding of removal.

Statutory list of documents that establish conviction for a predicate offense is not an exhaustive list of the manner in which the predicate offense can be proved.

Administrative challenge that the petitioner's conviction was not established by the statutory list does not appropriately exhaust a claim that the predicate conviction does not justify a withholding of removal.

http://www.ca4.uscourts.gov/opinions/171213.P.pdf