The Fourth Circuit has deferred to the Board of Immigration Appeals’ determination that receipt of stolen property offenses constitute crimes involving moral turpitude (CIMT) if the defendant knows the property was stolen, even if the statutes do not require the defendant to intend to permanently deprive the owner of the property. The court further agreed that Virginia’s receipt of stolen property statute matches the definition of a CIMT. The court remanded because the Immigration Judge failed to advise the petitioner of the requirement of posting a voluntary departure bond before granting him voluntary departure.

The full text of Solis-Flores v. Garland can be found here:

https://www.ca4.uscourts.gov/opinions/221147.P.pdf

Comment