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BIA Seeks Amicus Briefs on Divisibility of Iowa Theft Statute

March 16, 2021 (1 min read)

BIA, Mar. 15, 2021

"Amicus Invitation No. 21-15-03 AMICUS INVITATION (Divisibility of Iowa’s Theft Statute) Due Date: April 14, 2021 March 15, 2021 The Board of Immigration Appeals welcomes interested members of the public to file amicus curiae briefs discussing the below issue: ISSUE PRESENTED: Whether Iowa’s theft statute, which is codified at Iowa Code § 714.1, is divisible as to thefts by takings and thefts by fraud, pursuant to the approach set forth in Mathis v. United States, 136 S. Ct. 2243 (2016), and Descamps v. United States, 570 U.S. 254 (2013), in light of the Iowa state court decisions in State v. Nall, 894 N.W. 2d 514 (Iowa 2017), State v. Conger, 434 N.W.2d 406 (Iowa Ct. App. 1988), and State v. Williams, 328 N.W.2d 504 (Iowa 1983)."