Ninth Circuit

AGGRAVATED FELONY - FRAUD OFFENSE - FALSE STATEMENT TO GOVERNMENT OFFICIAL
Li v. Ashcroft, 389 F.3d 892 (9th Cir. Nov. 19. 2004) (conviction of making a false statement to a United States official, in violation of 18 U.S.C. 1001, is divisible with respect to the fraud offense aggravated felony defined in INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), since it does not require proof of any monetary loss and so does not automatically satisfy the element of this aggravated felony definition requiring a loss to the victim(s) in excess of $10,000, so the record of conviction must be examined to determine whether the conviction falls within the definition).