Rishi Ramdial closes the door on cancellation of removal for a Florida sudden-snatching conviction.
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The decision. In Rishi Ramdial v. U.S. Attorney General, No. 25-10093 (11th Cir. Aug. 21, 2026), the Eleventh Circuit held that a Florida conviction for robbery by sudden snatching, Fla. Stat. § 812.131(1), is a "theft offense" and so an aggravated felony under 8 U.S.C. § 1101(a)(43)(G). The court first held the statute is not divisible: its "permanently or temporarily" and "victim or the owner" phrasings are different ways to satisfy one intent element, not separate elements, so the record of conviction is off limits. Comparing the least culpable conduct the statute reaches to generic theft, the court found a match and denied the petition for review.
What it means. Two points do the work. Generic theft does not require an intent to deprive the titleholder; an intent to take from someone with a superior possessory interest is enough. And a deprivation counts "even if such deprivation is less than total or permanent." The court distinguished the vehicle-use cases petitioners often cite, including Castillo v. Holder, 776 F.3d 262 (4th Cir. 2015), and Da Graca v. Garland, 23 F.4th 106 (1st Cir. 2022), as reaching joyriding and "glorified borrowing" that Florida's statute does not. The practical result: a lawful permanent resident with this conviction and a sentence of at least one year cannot obtain cancellation of removal under 8 U.S.C. § 1229b(a).
For the Eleventh Circuit. This rule now governs cases from the immigration courts in Florida and Georgia, including Miami, Krome, Orlando, Atlanta, and Stewart. Note the procedural history: Ramdial raised his strongest categorical arguments for the first time in the court of appeals, and the case went back to the Board of Immigration Appeals before it could be decided. The appeal is built at the Immigration Court and before the Board or it is not built at all.
The limits. Ramdial binds only the Eleventh Circuit, and it addresses only Fla. Stat. § 812.131(1). It does not disturb Jaggernauth v. U.S. Attorney General, 432 F.3d 1346 (11th Cir. 2005), which treats Florida's general theft statute as divisible, and it decides nothing about relief other than cancellation. Ramdial's separate removability for controlled-substance convictions was never contested here.
Case Law Watch is Emeriti Law's weekly note on decisions that matter for immigration appeals. Our appellate practice briefs these questions before the Board of Immigration Appeals. This note is general information, not legal advice.
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