The Third Circuit has determined that a New Jersey conviction for second-degree robbery is a theft-related aggravated felony because the statute always requires that property be obtained without the owner’s voluntary and intelligent assent. Notably, the court includes various of forms of theft-by-deception in this definition of crimes committed without voluntary and intelligent assent.

The full text of K.A. v. Attorney General can be found here:

https://www2.ca3.uscourts.gov/opinarch/173640p.pdf

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