CA1 on CIMT, Modified Categorical Approach: Patel v. Holder

"In 2003, petitioner Nupur Patel pled guilty to conspiracy-to-commit-larceny charges stemming from a  scheme in which he stole from the dorm rooms of his college classmates.  As a result, an Immigration Judge (IJ) and the Board of Immigration Appeals (BIA) found that Patel, at the time a lawful permanent resident, was removable from the United States because his crimes involved "moral turpitude" within the meaning of the Immigration and Nationality Act (INA).  Patel now seeks our review of that determination.  Because the BIA's ruling does not find adequate support in the record, we reverse." - Patel v. Holder, Feb. 1, 2013.  [Hats off to Justin Conlon!]