The Eleventh Circuit has denied a petition for review filed by a Trinidadian lawful permanent resident found ineligible for cancellation of removal based on a Florida robbery-by-sudden-snatching conviction, holding the offense categorically matches generic theft as an aggravated felony.
The Court held that generic theft requires only an intent to deprive someone with a superior possessory interest, not a title-owner, and that Florida's statute and standard jury instructions require exactly the same showing even where the direct victim is not the property's ultimate owner. The Court also held the statute's coverage of temporary as well as permanent deprivations does not create a mismatch, since generic theft likewise reaches less-than-permanent deprivations, and that the statute's requirement that the victim be unaware of or unwilling to permit the taking supplies the functional equivalent of a lack-of-consent element.
The full text of Ramdial v. U.S. Attorney General can be found here: https://media.ca11.uscourts.gov/opinions/pub/files/202510093.pdf