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).