United States Fourth Circuit

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Mohamed v. Holder, 13-2027

Petition for review of an order of removal on grounds that petitioner had been convicted of two crimes "involving moral turpitude" is granted, and the Board of Immigration Appeals (BIA) ruling is reversed and remanded with instructions to vacate the order of removal, where: 1) 8 U.S.C. section 1227(a)(2)(A)(ii) renders deportable an alien who is convicted of two or more crimes involving moral turpitude; 2) the BIA erred in relying on its prior decision in Matter of Tobar-Lobo to conclude that failure to register could constitute a crime involving moral turpitude, as Tobar-Lobo was an unreasonable interpretation of section 1227(a)(2)(A)(ii); and 3) having been convicted of only one crime involving moral turpitude, petitioner was not rendered deportable.

Appellate Information

  • Decided 10/17/2014
  • Published 10/17/2014


  • Niemeyer


  • United States Fourth Circuit


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