Ilchuk v. Attorney General, 434
F.3d 618 (3d Cir. Jan. 17, 2006) (Pennsylvania conviction
of theft of services, in violation of 18 Penn. Consol. Stats.
Ann. § 3926(b) ("guilty of theft if, having control over
the disposition of services of others to which he is not entitled,
he knowingly diverts such services to his own benefit or to
the benefit of another not entitled thereto."), with
a six- to 23-month sentence to home arrest, constituted theft
offense aggravated felony under INA § 101(a)(43)(G), 8 U.S.C.
§ 1101(a)(43)(G), for immigration purposes because the offense
requires the taking or exercise of control over something
of value knowing that its owner has not consented).