Aggravated Felonies
§ 5.21 (A)
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(A) Property. While 18 U.S.C. § 16 includes offenses involving violence against property,[146] within the aggravated felony immigration definition of crime of violence, another definition, applied in the illegal re-entry sentencing context, applies only to crimes involving violence against persons. See § 4.40, supra.
[146] See, e.g., Matter of Palacios-Pinera, 22 I. & N. Dec. 434 (BIA Dec. 18, 1998) (en banc) (Alaska conviction of arson in the first degree under section 11.46.400 of the Alaska Statutes, with a seven-year sentence, was a “crime of violence” and therefore an aggravated felony under INA § 101(a)(43)(F), 8 U.S.C. § 1101(a)(43)(F)).
