Ferreira v. Ashcroft, 390 F.3d 1091
(9th Cir. Dec. 1, 2004) (California conviction of welfare
fraud, in violation of Welf. & Inst. Code § 10980(c)(2),
as interpreted by California judicial decisions defining the
elements of the offense, invariably requires an element of
fraud or deceit, and therefore constitutes an offense involving
fraud or deceit for purposes of qualifying as an aggravated
felony as defined under INA § 101(a)(43)(M)(i), 8 U.S.C. §
1101(a)(43)(M)(i) triggering deportation).