In this unpublished decision, the Board of Immigration Appeals (BIA) held that grand larceny under Va. Code Ann. 18.2-95 is not a categorical theft-related aggravated felony under INA 101(a)(43)(G) because the statute can be applied to fraud offenses. The Board also stated that the Supreme Court’s decision in Descamps v. United States, 133 S.Ct. 2276 (2013), overruled Matter of Lanferman, 25 I&N Dec. 721 (BIA 2012), on whether a criminal statute is divisible. The Board concluded, however, that Va. Code Ann. 18.2-95 is divisible under Descamps and that the conviction record demonstrated that the respondent committed a theft- rather than fraud-related offense. The decision was written by Member Patricia Cole.