In an earlier case, the BIA clarified that under federal law, a “theft offense” under INA section 101(a)(43)(G) is defined as the “taking of, or exercise of control over, property without consent….”Matter ofGarcia-Madruga, 24 I&N Dec. 436, 440 (BIA 2008). In addition, there was BIA caselaw following Garcia-Madruga that held that larceny in the third degree (an offense identical to Mr. P.’s statute of conviction for all material purposes) was not categorically an aggravated felony.