NEW BIA PRECEDENT: CAL. ROBBERY IS CATEGORICAL AGFEL — Matter of Delgado, 27 I&N Dec. 100 (BIA 2017)

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BIA HEADNOTE:

“Robbery under section 211 of the California Penal Code, which includes the element of asportation of property, is categorically an aggravated felony theft offense under section 101(a)(43)(G) of the Immigration and Nationality Act, 8 U.S.C. § 1101(a)(43)(G) (2012), regardless of whether a violator merely aided or abetted in the asportation of property stolen by a principal.”

PANEL: BIA Appellate Immigration Judges Pauley, Guendelsberger, Malphrus

OPINION BY:  Judge Pauley

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PWS

09-12-17