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Ben Winograd writes: "In this unpublished decision, the Board of Immigration Appeals (BIA) terminated proceedings upon finding fourth degree arson under N.Y.P.L. 150.05 not to be a categorical crime involving moral turpitude because perpetrators need have a specific intent to damage property. The Board also found the statute was not subject to the modified categorical approach under Descamps v. United States, 133 S. Ct. 2276 (2013), which it said overruled the Board’s prior decision on divisibility in Matter of Lanferman, 25 I&N Dec. 721 (BIA 2012)." - Matter of Hernandez-Hernandez, (BIA May 20, 2014, unpub.)