Decision date: 2017-04-25

Holding that Virginia statutory burglary conviction under Va. Code § 18.2-91 is categorically not an aggravated felony burglary offense under 8 U.S.C. § 1101(a)(43)(G) because the statute is indivisible, containing several alternative means for committing the offense, and overbroad, encompassing lawful entry and entry without force.

Publication Status: Published

Case judge: Davis, Gregory, King

Decision: Castendet-Lewis v. Sessions, 855 F.3d 253 (4th Cir. 2017)