BIA

FORGERY
Matter of Aldabesheh, 22 I. & N. Dec. 983 (BIA Aug. 30, 1999) (en banc) (New York conviction for forgery in the second degree, in violation of section 170.10(2) of the New York Penal Law, is an aggravated felony under INA § 101(a)(43)(R), 8 U.S.C. § 1101(a)(43)(R)).

AGGRAVATED FELONY - FORGERY - DOCUMENT FORGERY
Vizcarra-Ayala v. Mukasey, __ F.3d __, 2008 WL 184954 (9th Cir. Jan. 23, 2008) (California conviction for violation of California Penal Code 475(c) is not categorically an aggravated felony offense "related to" forgery, because the statute encompasses real, unaltered documents, and thus falls outside the generic definition of "forgery" applied to the aggravated felony category).

First Circuit

FORGERY
United States v. Johnstone, 251 F.3d 281 (1st Cir. June 5, 2001) (Colorado conviction for forgery, on which a one-year sentence was imposed, constituted an aggravated felony under INA § 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R), warranting sentence enhancement for illegal re-entry under U.S.S.G. § 2L1.2(b)(1)(A)).

Second Circuit

POSSESSION OF FORGED DOCUMENT - FORGERY
Richards v. Ashcroft, 400 F.3d 125 (2d Cir. Mar. 3, 2005) (Connecticut conviction of possession of a forged document with intent to defraud, deceive, or injure, in violation of Conn. Gen. Stat. § 53a-139, is "an offense relating to . . . forgery" within the meaning of INA § 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R), and is therefore an aggravated felony for deportation purposes under INA § 237(a)(2)(A)(iii), 8 U.S.C. § 1227(a)(2)(A)(iii)).

Third Circuit

FORGERY
Drakes v. Zimski, 240 F.3d 246 (3d Cir. Feb. 20, 2001) (Delaware conviction for forgery in violation of 11 Del.C. § 861, with one-year sentence imposed, was "aggravated felony," under INA § 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R), causing Court of Appeals to lose jurisdiction to consider petition for review of deportation order).

Sixth Circuit

AGGRAVATED FELONY - COUNTERFEITING - FORGERY
Nwagbo v. Holder, 571 F.3d 508, 511 (6th Cir. Jul. 13, 2009) (federal conviction of conspiracy to possess counterfeited obligations of the United States with intent to defraud, in violation of 18 U.S.C. 472 ("(1) the false bill passed or possessed is counterfeit, 2) the defendant intended to use the false bill to defraud, and 3) the defendant passed or possessed the false bill."), constituted a conviction for an aggravated felony "offense relating to ... counterfeiting," under INA 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R), since "'[s]ection 101(a)(43)(R) [of the INA] necessarily covers a range of activities beyond those of counterfeiting or forgery itself.'").

Eighth Circuit

AGGRAVATED FELONY - FORGERY - POSSESSION OF FORGED DOCUMENTS
United States v. Chavarria-Brito, 526 F.3d 1184 (8th Cir. May 29, 2008) (Iowa conviction for possession of false document required to legally enter, remain, or work in this country with intent to perpetrate fraud or with knowledge that possession was facilitating fraud, in violation of Iowa Code 715A.2(1)(d) and 715A.2(2)(a)(4), was an "offense related to forgery" aggravated felony under INA 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R), for purposes of imposing an eight-level sentencing enhancement under USSG 2L1.2(b)(1)(C) for illegal reentry after deportation).

Eleventh Circuit

AGGRAVATED FELONY " FORGERY OFFENSES " POSSESSION OF FORGED DOCUMENTS
United States v. Martinez-Gonzalez, 663 F.3d 1305 (11th Cir. Dec. 6, 2011) (per curiam) (Alabama conviction of possession of forged documents with intent to defraud, in violation of Ala.Code 13A"9"6, constituted an aggravated felony forgery offense, under INA 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R), because it was an offense related to forgery); accord, United States v. Chavarria"Brito, 526 F.3d 1184, 1186 (8th Cir. 2008) (conviction for the possession of a false document with the intent to perpetrate a fraud constitutes an aggravated felony under U.S.S.G. 2L1.2(b)(1)(C)); Richards v. Ashcroft, 400 F.3d 125, 130 (2d Cir.2005); Albillo"Figueroa v. INS, 221 F.3d 1070 (9th Cir. 2000).