Soliman v. Gonzalez, 419 F.3d 276 (4th Cir. Aug. 22, 2005) (fraudulent use of a credit card, in violation of Virginia Code 18.2-195, where the actor uses a credit card belonging to a different person without that persons authorization to obtain something of value is not an aggravated felony theft offense, but a fraud offense).
jurisdiction:
Fourth Circuit