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BIA on Theft, AgFel: Matter of Koat

January 27, 2022 (1 min read)

Matter of Koat, 28 I&N Dec. 450 (BIA 2022) - Section 714.1 of the Iowa Code is divisible with respect to whether a violation of the statute involved theft by taking without consent or theft by fraud or deceit, permitting an Immigration Judge to review the conviction record under a modified categorical approach to determine whether the violation involved aggravated felony theft as defined in section 101(a)(43)(G) of the Immigration and Nationality Act, 8 U.S.C. § 1101(a)(43)(G) (2018).