The Third Circuit has determined that the Board of Immigration Appeals’ decision in Matter of Diaz-Lizarraga, which broadened the definition of a theft-related crime involving moral turpitude, cannot be applied retroactively to a conviction sustained before the decision in Diaz-Lizarraga.
The full text of Francisco-Lopez v. Attorney General can be found here:
https://www2.ca3.uscourts.gov/opinarch/192700p.pdf