Matter of Samuel Alberto IBARRA, 26 I&N Dec. 809 (BIA 2016)

In a decision published September 15, 2016, the BIA determines that a "theft offense" includes theft via extortion. https://www.justice.gov/sites/default/files/pages/attachments/2016/09/15/3872.pdf

(1) A “theft offense” under section 101(a)(43)(G) of the Immigration and Nationality Act, 8 U.S.C. § 101(a)(43)(G) (2012), which requires the taking of property “without consent,” includes extortionate takings, in which consent is coerced by the wrongful use of force, fear, or threats. (2) Robbery by force or fear in violation of section 211 of the California Penal Code is categorically an aggravated felony theft offense under section 101(a)(43)(G) of the Act.

(2) Robbery by force or fear in violation of section 211 of the California Penal Code is categorically an aggravated felony theft offense under section 101(a)(43)(G) of the Act.

Full Decision Matter of Samuel Alberto IBARRA, 26 I&N Dec. 809 (BIA 2016)