The Board of Immigration Appeals (Board) has issued a pair of companion cases addressing when theft crimes are properly considered to be crimes involving moral turpitude (CIMT). In Matter of Diaz-Lizarraga, the Board determined that a conviction for theft would qualify as a CIMT if it required an intent to permanently deprive the owner of the property or circumstances where the owner's property rights are substantially eroded. The Board then determined that a conviction for shoplifting in Arizona categorically qualified as a CIMT. In Matter of Obeya, the Board applied this new definition to determine that conviction for petit larceny in New York is also a CIMT.
The full text of Matter of Diaz-Lizarraga can be found here:
The full text of Matter of Obeya can be found here: