Choeum v. INS, 129 F.3d 29 (1st Cir.
Nov. 5, 1997) (New York conviction of kidnapping was crime
of violence under 18 U.S.C. § 16(a), since it had force as
an element, and therefore constituted an "aggravated
felony " under INA § 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F)
for immigration purposes).

jurisdiction: 
First Circuit

 

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