Multiple CIMTs and the Single-Scheme Exception

How INA §237(a)(2)(A)(ii) treats two or more crimes involving moral turpitude and when offenses arise out of a single scheme of criminal misconduct.

Two or more CIMT convictions after admission can support deportability if they do not arise out of a single scheme of criminal misconduct. Matter of Baeza-Galindo emphasizes that close timing alone is not enough; separate turpitudinous acts with distinct criminal objectives can constitute separate schemes.

For multiple CIMTs single scheme, the practitioner should map the multiple CIMTs single scheme charge before making concessions. The multiple CIMTs single scheme map should identify the conviction, the multiple CIMTs single scheme statutory comparator, the governing multiple CIMTs single scheme method, and the evidence that current multiple CIMTs single scheme law permits.

The multiple-CIMT ground requires at least two CIMT convictions and excludes offenses that arise out of a single scheme of criminal misconduct.

Within multiple CIMTs single scheme, this proposition defines the multiple CIMTs single scheme dispute. The clause “The multiple-CIMT ground requires at least two CIMT convictions and excludes” must be linked to multiple CIMTs single scheme authority before “offenses that arise out of a single scheme of criminal misconduct.” is treated as established. Matter of Baeza-Galindo, 29 I&N Dec. 1 (BIA 2025) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 1 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Unlike the single-CIMT ground, §237(a)(2)(A)(ii) contains no five-year-after-admission limitation and no one-year potential-sentence requirement.

Within multiple CIMTs single scheme, this proposition narrows the multiple CIMTs single scheme dispute. The clause “Unlike the single-CIMT ground” must be linked to multiple CIMTs single scheme authority before “§237(a)(2)(A)(ii) contains no five-year-after-admission limitation and no one-year potential-sentence requirement.” is treated as established. Matter of Islam, 25 I&N Dec. 637 (BIA 2011) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 2 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Matter of Baeza-Galindo explains that temporal proximity is relevant but not dispositive; the inquiry focuses on whether the respondent performed separate turpitudinous acts rather than one indivisible criminal episode.

Within multiple CIMTs single scheme, this proposition controls the multiple CIMTs single scheme dispute. The clause “Matter of Baeza-Galindo explains that temporal proximity is relevant but not dispositive” must be linked to multiple CIMTs single scheme authority before “the inquiry focuses on whether the respondent performed separate turpitudinous acts rather than one indivisible criminal episode.” is treated as established. Matter of Adetiba, 20 I&N Dec. 506 (BIA 1992) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 3 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

An intervening opportunity to reflect can support a finding of separate schemes, but the analysis is not reduced to a stopwatch.

Within multiple CIMTs single scheme, this proposition structures the multiple CIMTs single scheme dispute. The clause “An intervening opportunity to reflect can support a finding of separate schemes” must be linked to multiple CIMTs single scheme authority before “but the analysis is not reduced to a stopwatch.” is treated as established. Matter of Baeza-Galindo, 29 I&N Dec. 1 (BIA 2025) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 4 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Different victims, locations, objectives, or completed criminal acts can support separate-scheme treatment even when the offenses occur in a short period.

Within multiple CIMTs single scheme, this proposition changes the multiple CIMTs single scheme dispute. The clause “Different victims” must be linked to multiple CIMTs single scheme authority before “locations” is treated as established. Matter of Islam, 25 I&N Dec. 637 (BIA 2011) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 5 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Conversely, multiple counts or statutory convictions can still arise from one scheme where they are closely connected parts of a single criminal episode under controlling precedent.

Within multiple CIMTs single scheme, this proposition directs the multiple CIMTs single scheme dispute. The clause “Conversely” must be linked to multiple CIMTs single scheme authority before “multiple counts or statutory convictions can still arise from one scheme where they are closely connected parts of a single criminal episode under controlling precedent.” is treated as established. Matter of Adetiba, 20 I&N Dec. 506 (BIA 1992) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 6 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Each conviction must independently qualify as a CIMT before the single-scheme issue matters.

Within multiple CIMTs single scheme, this proposition governs the multiple CIMTs single scheme dispute. The clause “Each conviction must independently qualify as” must be linked to multiple CIMTs single scheme authority before “a CIMT before the single-scheme issue matters.” is treated as established. Matter of Baeza-Galindo, 29 I&N Dec. 1 (BIA 2025) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 7 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

The record should separate the elements analysis from the factual single-scheme analysis; the latter can require evidence beyond merely naming the statutes.

Within multiple CIMTs single scheme, this proposition resolves the multiple CIMTs single scheme dispute. The clause “The record should separate the elements analysis from the factual single-scheme analysis” must be linked to multiple CIMTs single scheme authority before “the latter can require evidence beyond merely naming the statutes.” is treated as established. Matter of Islam, 25 I&N Dec. 637 (BIA 2011) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 8 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Counsel should obtain charging instruments, plea records, judgments, police chronology where admissible for the issue, and sentencing materials that show how the acts relate.

Within multiple CIMTs single scheme, this proposition frames the multiple CIMTs single scheme dispute. The clause “Counsel should obtain charging instruments” must be linked to multiple CIMTs single scheme authority before “plea records” is treated as established. Matter of Adetiba, 20 I&N Dec. 506 (BIA 1992) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 9 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

If DHS charges both §237(a)(2)(A)(i) and (ii), the respondent should analyze each ground independently because winning the single-scheme issue does not necessarily defeat a valid single-CIMT charge.

Within multiple CIMTs single scheme, this proposition limits the multiple CIMTs single scheme dispute. The clause “If DHS charges both §237(a)(2)(A)(i) and (ii)” must be linked to multiple CIMTs single scheme authority before “the respondent should analyze each ground independently because winning the single-scheme issue does not necessarily defeat a valid single-CIMT charge.” is treated as established. Matter of Baeza-Galindo, 29 I&N Dec. 1 (BIA 2025) supplies a published multiple CIMTs single scheme reference for the legal method or qualifier involved.

A multiple CIMTs single scheme record on rule 10 should identify the multiple CIMTs single scheme document proving the conviction, the multiple CIMTs single scheme source proving the legal rule, and the multiple CIMTs single scheme fact that remains disputed. That rule-specific multiple CIMTs single scheme structure keeps allegations from replacing the legally operative multiple CIMTs single scheme requirement.

Matter of Baeza-Galindo, 29 I&N Dec. 1 (BIA 2025) matters to multiple CIMTs single scheme because its holding addresses a multiple CIMTs single scheme component reflected in this rule: The multiple-CIMT ground requires at least two CIMT convictions and excludes offenses that arise out of a single scheme of criminal misconduct.

Applying Matter of Baeza-Galindo, 29 I&N Dec. 1 (BIA 2025) to multiple CIMTs single scheme also requires attention to this separate multiple CIMTs single scheme proposition: Unlike the single-CIMT ground, §237(a)(2)(A)(ii) contains no five-year-after-admission limitation and no one-year potential-sentence requirement. The multiple CIMTs single scheme brief should use the case for those propositions and avoid extending the multiple CIMTs single scheme holding beyond its procedural posture.

Matter of Islam, 25 I&N Dec. 637 (BIA 2011) matters to multiple CIMTs single scheme because its holding addresses a multiple CIMTs single scheme component reflected in this rule: Matter of Baeza-Galindo explains that temporal proximity is relevant but not dispositive; the inquiry focuses on whether the respondent performed separate turpitudinous acts rather than one indivisible criminal episode.

Applying Matter of Islam, 25 I&N Dec. 637 (BIA 2011) to multiple CIMTs single scheme also requires attention to this separate multiple CIMTs single scheme proposition: An intervening opportunity to reflect can support a finding of separate schemes, but the analysis is not reduced to a stopwatch. The multiple CIMTs single scheme brief should use the case for those propositions and avoid extending the multiple CIMTs single scheme holding beyond its procedural posture.

Matter of Adetiba, 20 I&N Dec. 506 (BIA 1992) matters to multiple CIMTs single scheme because its holding addresses a multiple CIMTs single scheme component reflected in this rule: Different victims, locations, objectives, or completed criminal acts can support separate-scheme treatment even when the offenses occur in a short period.

Applying Matter of Adetiba, 20 I&N Dec. 506 (BIA 1992) to multiple CIMTs single scheme also requires attention to this separate multiple CIMTs single scheme proposition: Conversely, multiple counts or statutory convictions can still arise from one scheme where they are closely connected parts of a single criminal episode under controlling precedent. The multiple CIMTs single scheme brief should use the case for those propositions and avoid extending the multiple CIMTs single scheme holding beyond its procedural posture.

A multiple CIMTs single scheme file should integrate three distinct multiple CIMTs single scheme propositions. First: The multiple-CIMT ground requires at least two CIMT convictions and excludes offenses that arise out of a single scheme of criminal misconduct. Second: An intervening opportunity to reflect can support a finding of separate schemes, but the analysis is not reduced to a stopwatch. Third: Each conviction must independently qualify as a CIMT before the single-scheme issue matters.

Those multiple CIMTs single scheme propositions determine the multiple CIMTs single scheme documents worth collecting. Certified records should prove multiple CIMTs single scheme elements and sentence; historical materials should prove multiple CIMTs single scheme timing when timing matters; broader proof should be reserved for a circumstance-specific multiple CIMTs single scheme qualifier. The final multiple CIMTs single scheme brief should assign each multiple CIMTs single scheme burden and request a precise multiple CIMTs single scheme ruling.

A multiple CIMTs single scheme file should integrate three distinct multiple CIMTs single scheme propositions. First: Unlike the single-CIMT ground, §237(a)(2)(A)(ii) contains no five-year-after-admission limitation and no one-year potential-sentence requirement. Second: Different victims, locations, objectives, or completed criminal acts can support separate-scheme treatment even when the offenses occur in a short period. Third: The record should separate the elements analysis from the factual single-scheme analysis; the latter can require evidence beyond merely naming the statutes.

Those multiple CIMTs single scheme propositions determine the multiple CIMTs single scheme documents worth collecting. Certified records should prove multiple CIMTs single scheme elements and sentence; historical materials should prove multiple CIMTs single scheme timing when timing matters; broader proof should be reserved for a circumstance-specific multiple CIMTs single scheme qualifier. The final multiple CIMTs single scheme brief should assign each multiple CIMTs single scheme burden and request a precise multiple CIMTs single scheme ruling.

A multiple CIMTs single scheme file should integrate three distinct multiple CIMTs single scheme propositions. First: Matter of Baeza-Galindo explains that temporal proximity is relevant but not dispositive; the inquiry focuses on whether the respondent performed separate turpitudinous acts rather than one indivisible criminal episode. Second: Conversely, multiple counts or statutory convictions can still arise from one scheme where they are closely connected parts of a single criminal episode under controlling precedent. Third: Counsel should obtain charging instruments, plea records, judgments, police chronology where admissible for the issue, and sentencing materials that show how the acts relate.

Those multiple CIMTs single scheme propositions determine the multiple CIMTs single scheme documents worth collecting. Certified records should prove multiple CIMTs single scheme elements and sentence; historical materials should prove multiple CIMTs single scheme timing when timing matters; broader proof should be reserved for a circumstance-specific multiple CIMTs single scheme qualifier. The final multiple CIMTs single scheme brief should assign each multiple CIMTs single scheme burden and request a precise multiple CIMTs single scheme ruling.

A multiple CIMTs single scheme file should integrate three distinct multiple CIMTs single scheme propositions. First: An intervening opportunity to reflect can support a finding of separate schemes, but the analysis is not reduced to a stopwatch. Second: Each conviction must independently qualify as a CIMT before the single-scheme issue matters. Third: If DHS charges both §237(a)(2)(A)(i) and (ii), the respondent should analyze each ground independently because winning the single-scheme issue does not necessarily defeat a valid single-CIMT charge.

Those multiple CIMTs single scheme propositions determine the multiple CIMTs single scheme documents worth collecting. Certified records should prove multiple CIMTs single scheme elements and sentence; historical materials should prove multiple CIMTs single scheme timing when timing matters; broader proof should be reserved for a circumstance-specific multiple CIMTs single scheme qualifier. The final multiple CIMTs single scheme brief should assign each multiple CIMTs single scheme burden and request a precise multiple CIMTs single scheme ruling.

A multiple CIMTs single scheme file should integrate three distinct multiple CIMTs single scheme propositions. First: The multiple-CIMT ground requires at least two CIMT convictions and excludes offenses that arise out of a single scheme of criminal misconduct. Second: Conversely, multiple counts or statutory convictions can still arise from one scheme where they are closely connected parts of a single criminal episode under controlling precedent. Third: If DHS charges both §237(a)(2)(A)(i) and (ii), the respondent should analyze each ground independently because winning the single-scheme issue does not necessarily defeat a valid single-CIMT charge.

Those multiple CIMTs single scheme propositions determine the multiple CIMTs single scheme documents worth collecting. Certified records should prove multiple CIMTs single scheme elements and sentence; historical materials should prove multiple CIMTs single scheme timing when timing matters; broader proof should be reserved for a circumstance-specific multiple CIMTs single scheme qualifier. The final multiple CIMTs single scheme brief should assign each multiple CIMTs single scheme burden and request a precise multiple CIMTs single scheme ruling.