The Seventh Circuit determined that a conviction under a Florida statute criminalizing uttering a false instrument necessarily entails a knowingly deceitful act, and thus, qualifies as a fraud-based aggravated felony if the crime resulted in a loss to the victim in excess of $10,000.  For the same reason, the conviction qualifies as a crime involving moral turpitude.

The full text of Walker v. Attorney General can be found here: http://media.ca11.uscourts.gov/opinions/pub/files/201412814.pdf

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