Soliman v. Gonzales, 419 F.3d 276 (4th Cir. Aug. 22, 2005)
(Virginia conviction of fraudulent use of a credit card, in
violation of Virginia Code § 18.2-195, with intent to obtain
$200.00 in property, is not an aggravated felony theft offense;
the BIA erred in finding that fraud offenses necessarily included
theft; theft is distinguishable from fraud, in that theft
requires the taking of property without consent, while fraud
requires an intent to deprive through consent obtained through
misrepresentation).