Prus v. Holder, 660 F.3d 144 (2d Cir. Sept. 28, 2011) (New York conviction for promoting prostitution in the third degree, under New York Penal Law 20.00 and 230.25, does not constitute an aggravated felony within the meaning of INA 101(a)(43)(K)(i), 8 U.S.C. 1101(a)(43)(K)(i), because New York law defines prostitution more broadly than the generic federal definition of this aggravated felony offense).
jurisdiction:
Second Circuit