Kawashima v. Holder

Summary

The Court held that convictions under 26 U.S.C. §§ 7206(1) and (2) qualify as aggravated felonies under 8 U.S.C. § 1101(a)(43)(M)(i) when the government loss exceeds $10,000. The Court found these offenses necessarily entail deceit under the categorical approach, and affirmed the Ninth Circuit. Justice Ginsburg, dissenting, argued this interpretation renders Clause (ii) superfluous.