The Fourth Circuit has determined that Maryland's petty theft statute does not match the generic definition of a crime involving moral turpitude (CIMT). Maryland’s theft statute does not distinguish between substantial and de minimis takings as required to qualify as a CIMT under Matter of Diaz-Lizarraga. The Court further concluded that the statute is indivisible, and as such, use of the modified categorical approach was inappropriate.
The full text of Levya Martinez v. Sessions can be found here: