The BIA refined its interpretation of the “single scheme of criminal misconduct” exception to the multiple crimes involving moral turpitude ground of removal. Matter of Islam, 25 I&N Dec. 637 (BIA 2011) (Pauley, Malphrus, and Mullane, Board Members). Board Member Pauley wrote the panel’s opinion. This case involved an LPR who was convicted of criminal possession of stolen property (involving a credit or debit card), N.Y. Penal § 165.45(2), and, four months later, forgery in the third degree, N.Y. Penal § 170.05. DHS charged him as removal pursuant to INA § 237(a)(2)(A)(ii) for having [...]