Safe Havens

            For nearly all aggravated felony categories, there is an argument that when Congress expressly included the non-substantive offenses of attempt and conspiracy, it in effect excluded all other non-substantive offenses, such as solicitation.  See § 7.12, supra.  Similar arguments are available with respect to most other grounds of deportation.  See, e.g., § § 7.107 (crimes of moral turpitude), 7.141 (controlled substances), 7.151 (domestic violence offenses), and 7.176 (firearms offenses), infra.  See generally Appendix H, Non-Substantive Offenses, infra.