In a decision perhaps more interesting for its discussion of privacy interests and Fourth Amendment law, the Eighth Circuit reaffirmed, in light of the Supreme Court's decision in Descamps v. US, that second-degree burglary in Missouri (including commercial burglary) matches the generic definition of a burglary offense.  Though this finding was made in the context of a federal criminal sentencing action, it has implications for immigration practitioners.  If second-degree burglary in Missouri matches the federal generic definition of a burglary offense, then a conviction for second-degree burglary in Missouri that is accompanied by a sentence of 1 year or more is very likely an aggravated felony for immigration purposes under section 101(A)(43)(G) of the Immigration and Nationality Act.  

You can read the full text of US v. Bearden (including the more interesting Fourth Amendment/suppression analysis) here: