Patel v. Ashcroft, 294 F.3d 465 (3d Cir. June 20,
2002) (federal conviction of harboring an undocumented noncitizen,
in violation of INA § 101(a)(1)(A), 8 U.S.C. 1324(a)(1)(A),
met the definition of an "aggravated felony" under
INA § 101(a)(43)(N), 8 U.S.C. 1101(a)(43)(N), for immigration
purposes, despite the fact that defendant had no part in the
harbored persons illegal admission or entry).