Matter
of VFD, 23 I. & N. Dec. 859 (BIA 2006) (Florida conviction
for unlawful sexual activity with a minor, in violation of
Fla. Stat. Ann. § 794.05(1), is an aggravated felony sexual
abuse of a minor offense under INA § 101(a)(43)(A), 8 U.S.C.
§ 1101(a)(43)(A), for immigration purposes; victim of sexual
abuse who is under the age of 18 is a "minor" for
purposes of determining whether a noncitizen has been convicted
of sexual abuse of a minor).