The Board of Immigration Appeals (BIA) has determined that an Oregon conviction for burglary of a dwelling is a crime involving moral turpitude, even though it does not require that the burglar intend to commit a morally turpitudinous act after entry.  Instead, the BIA relied on its prior rationale in Matter of Louissant that burglary of a dwelling "tears away the resident’s justifiable expectation of privacy and personal security and invites a violent defensive response from the resident."  Even though the Oregon statute does not require the dwelling to be occupied at the time of the offense, it requires to be intermittently occupied, which the BIA found sufficient to invoke the concerns of Loussaint.

The full text of Matter of J-G-D-F- can be found here: