Board Issues Precedent Decision in the Matter of Ibarra, 26 I&N Dec. 809 (BIA 2016)

In the Matter of Ibarra, 26 I&N Dec. 809 (BIA 2016), the BIA held that INA aggravated felony provision for a “theft offense” in sec 101(a)(43)(G) includes extortionate takings. The Board found that a California statute for robbery by force or fear is categorically an aggravated felony theft offense under INA 101(a)(43)(G).