In this unpublished decision, the Board of Immigration Appeals (BIA) sustained the respondent’s appeal and terminated proceedings upon finding a fourth degree sexual offense under former Md. Code Ann. Art. 27, § 464C, is not a categorical crime of violence under 18 U.S.C. 16(a) because the statute does not require the use of force. The Board further found that use of the modified categorical approach was improper in light of the Supreme Court’s decision in Descamps v. United States, 133 S. Ct. 2276 (2013). The decision was written by Vice Chairman Charles Adkins-Blanch and joined by Member Anne Greer and Member Neil Miller.