Omari v. Gonzales, __ F.3d __, 2005 WL 1714364 (5th Cir. July 25, 2005) (federal conviction for interstate transportation of stolen, converted, and fraudulently obtained property, in violation of 18 U.S.C. 2314, is not an aggravated felony under INA 101(a)(43)(M)(i) (fraud) for immigration purposes, as not all parts of 18 U.S.C. 2314 necessarily involve fraud or deceit).
http://caselaw.lp.findlaw.com/data2/circs/5th/0361014p.pdf