In an unpublished decision, the Third Circuit found that a violation of Travel Act could be an aggravated felony.  Specifically, the court found that the Act is divisible, but the prong criminalizing the promotion, management, establishment, or carrying on of a business enterprise related to controlled substances qualified as a drug trafficking aggravated felony.  The court noted that the fact that the petitioner was convicted of engaging in a “business enterprise” suggested that his actions involved some sort of commercial element.

The full text of Deptula v. Attorney General can be found here: