New Case involving modified categorical approach: Under modified categorical approach, bank employee’s guilty plea to stealing, embezzling, and misapplying $65,000 of bank funds in violation of 18 U.S.C. Sec. 656 qualified as an aggravated felony under 8 U.S.C. Sec. 1101(a)(43)(M)(i) because the knowing misapplication of funds necessarily involved fraud.
Carlos-Blaza v. Holder
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Brian D. Lerner Immigration Attorney & Deportation Lawyer Blog 
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