appropriate in the immigration context where officials ‘exercise especially sensitive political functions that implicate questions of foreign relations.’ ” Id. at 425, 119 S.Ct. 1439 (quoting INS v. Abudu, 485 U.S. 94, 110, 108 S.Ct. 904, 99 L.Ed.2d 90 (1988)). Applying the principles of Chevron here, we conclude that Congress has not “directly spoken to the precise question at issue.” Chevron, 467 U.S. at 842, 104 S.Ct. 2778. The term “particularly serious crime” is open-ended, and the statute does not define it. And prior to the BIA’s decision in N-A-M-, the courts of appeal were divided over whether only aggravated felonies could be particularly serious crimes for purposes of withholding of removal. Compare Alaka v. Attorney Gen. of the United States, 456 F.3d 88, 105 (3d Cir.2006) (<HOLDING>), with Ali, 468 F.3d at 470 (rejecting that
holding that under the crimes code conspiracy and the completed substantive offense are separate crimes holding that particularly serious crimes must be aggravated felonies holding intoxication is only a defense to specific intent crimes and not general intent crimes holding that crimes of bank fraud punishable by up to five years imprisonment each were a serious offense for speedy trial act purposes holding that for purposes of double jeopardy analysis firstdegree felony murder and aggravated manslaughter are degree variants or aggravated forms of the core offense of homicide