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Matter of Baeza-Galindo
(1) Proximity in time is necessary but not sufficient to conclude that two crimes arise from a single scheme of criminal misconduct under section 237(a)(2)(A)(ii) of the Immigration and Nationality Act, 8 U.S.C. § 1227(a)(2)(A)(ii) (2018). Matter of Adetiba, 20 I&N Dec. 506, 509 (BIA 1992), clarified.
(2) Two crimes involving moral turpitude, premised on separate turpitudinous acts with different objectives, neither of which was committed in the course of accomplishing the other, constitute separate schemes of criminal misconduct.
"While driving under the influence of alcohol, the respondent struck a group of pedestrians with his truck, killing one of them and injuring the other three. He then drove away. The respondent was convicted of aggravated assault with a deadly weapon and of failing to stop and render aid. The Immigration Judge terminated proceedings, concluding that while the respondent had been convicted of two crimes involving moral turpitude, they arose out of a single scheme of criminal misconduct. We reverse."