The First Circuit has remanded a case to the Board of Immigration Appeals (BIA) to reconsider its finding that a Massachusetts arson conviction is categorically a crime involving moral turpitude.  The court noted that the statute includes burning one's own property.  The court also noted that Massachusetts law does not require evil intent nor a corrupt mindset for an arson conviction.

The full text of Rosa Pena v. Sessions can be found here: 

http://media.ca1.uscourts.gov/pdf.opinions/17-1310P-01A.pdf

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