Maryland Theft Statute as a Crime Involving Moral Turpitude
Marvin Brown, A*** *** *** (BIA June 8, 2018)(unpub) (holding that Md CR §7-104 is not a CIMT because it is nondivisible and “overbroad as to the requirement of moral turpitude,” because it criminalizes temporary takings that result in appropriation of any “part” of the property’s value, which is “insufficient to reach [the BIA’s] threshold of ‘substantially eroded’ property rights” established in Matter of Diaz-Lizarraga).
Vera Sama, A*** *** *** (BIA March 22, 2017, 2015) (unpub) (holding post-Mathis that Md CR §7-104 is not an aggravated felony because it is nondivisible and overbroad)
Clayton Hugh Anthony Stewart, A043 399 408 (BIA Feb. 11, 2015) (unpub) (holding that Md CR §7-104 is not an aggravated felony because it is nondivisible and overbroad)
Brief of Amici Curiae University of Maryland Carey School of Law Immigration Clinic; Maryland Office of the Public Defender; Immigrant & Refugee Appellate Center; and Maryland State Bar Association Immigration Section (Vera Sama, A076 581 488, BIA)