Ragoonath v. Holder

(1) Whether 18 U.S.C. § 656 is a crime "involving fraud or deceit" for purposes of the Immigration and Nationality Act"s definition of aggravated felony where the criminal statute does not contain either of these terms, but instead describes categorically a pure theft offense; and (2) whether, assuming that elements of an intent to defraud or to injure may be read into the statute, these are distinct mental states that render the statute divisible, such that 18 U.S.C. § 656 cannot categorically be classified as a fraud or deceit crime.