Matter of Fitzpatrick, 26 I&N Dec. 559 (BIA 2015) (noncitizen who has voted in a federal election, in violation of 18 U.S.C. 611(a), is removable under INA 237(a)(6)(A), 8 U.S.C. 1227(a)(6)(A) (2012), regardless of whether the alien knew that he or she was committing an unlawful act by voting).

Note: This conviction does not constitute a crime involving moral turpitude, because a scienter of strict liability is insufficiently culpable to qualify. See Leocal v. Ashcroft, 543 U.S. 1 (2004).