Matter of Rivens, 25 I&N Dec. 623, 627 n.5 (BIA Oct. 19, 2011) (federal conviction of accessory after the fact, in violation of 18 U.S.C. 3 (2000), is a crime involving moral turpitude, but only if the underlying offense is a crime involving moral turpitude); see Matter of Sanchez-Marin, 11 I&N Dec.

United States v. Reina-Rodriguez, 655 F.3d 1182 (9th Cir. Sept. 13, 2011) (Utah conviction of second-degree burglary of a dwelling, under Utah Code Ann. 76"6"202(2), did not categorically constitute a burglary of a dwelling crime of violence under U.S.S.G. 2L1.2(b)(1)(A)(ii) & n.1(B)(iii), because Utah law defined dwelling more broadly than it is defined in the federal Guidelines definition of burglary of a dwelling); following United States v.

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).

United States v. Rivera, 658 F.3d 1073 (9th Cir. Sept. 23, 2011) (California felony petty theft convictions under Penal Code 484(a) and 666 constituted aggravated felony theft offenses, under INA 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G), for illegal re-entry sentencing purposes); declining to follow United States v. Corona"Sanchez, 291 F.3d 1201 (9th Cir. 2002) (en banc); following United States v. Rodriquez, 553 U.S.

Habibi v. Holder, 658 F.3d 977 (9th Cir. Sept. 14, 2011) (the phrase "one year" is defined as 365 days, regardless of leap years; noncitizen was deportable for aggravated felony, under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F), even though his sentence was served during a leap year).

United States v. Wright, 625 F.3d 583 (9th Cir. Nov. 4, 2010) (no federal jurisdiction over an offense involving transmitted images that did not cross state lines).

United States v. Cruz-Rodriguez, 625 F.3d 274, 277 (5th Cir. Nov. 2, 2010) (per curiam) (California conviction of criminal threats, in violation of Penal Code 422, did not constitute a crime of violence under U.S.S.G.

Saavedra-Figueroa v. Holder, 625 F.3d 621 (9th Cir. Nov. 5, 2010) (California misdemeanor conviction of false imprisonment, in violation of Penal Code 236, was not a categorical crime of moral turpitude, because crime did not require noncitizen to have the intent to harm necessary for the crime to be base, vile or depraved).

United States v. Aguila-Montes de Oca, 655 F.3d 915 (9th Cir. Aug.

United States v. McMurray, 653 F.3d 367 (6th Cir. Aug 4, 2011) (Tennessee conviction of aggravated assault, in violation of Tenn.Code Ann. 39"13"102 (1991), was not a violent felony under the ACCAs use of physical force clause, or under its residual clause, for purposes of the Armed Career Criminal Act, where the offense could be committed recklessly).