Mejia v. Holder, ___ F.3d ___, 2014 WL 2872220 (1st Cir. Jun. 25, 2014) (the BIA's one-sentence conclusion, that alien's Massachusetts shoplifting conviction qualified as a crime involving moral turpitude, followed by cite to earlier BIA opinion finding that a violation of Pennsylvania's retail theft statute was a crime involving moral turpitude for immigration law purposes, was wholly insufficient and necessitated grant of petition for review, since it did not undertake any analysis of Massachusetts law or a categorical approach, because the BIA did not adequately consider the statutory issue presented, in that it failed to provide a comprehensible analysis to support its conclusion.).

 

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