Matter of Louissaint, 24 I. & N. Dec. 754 (BIA Mar. 18, 2009) (Florida conviction of burglary of an occupied dwelling, in violation of Florida Statutes 810.02(3)(a), is categorically a conviction for a crime involving moral turpitude, because there is no "realistic probability" that it would be applied to reach conduct that does not involve moral turpitude, and the offense, as defined by its statutory elements is one in which moral turpitude necessarily inheres: "We find . . . that moral turpitude is inherent in the act of burglary of an occupied dwelling itself, and that the respondents unlawful entry into the dwelling of another with the intent to commit any crime therein is a crime involving moral turpitude."), distinguishing Matter of M, 2 I. & N. Dec. 721 (BIA; A.G. 1946).

jurisdiction: 
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