Conejo Bravo v. Sessions, 875 F.3d 890 (9th Cir. Nov.17, 2017) (California conviction of hit and run, under Vehicle Code 20001(a), is under a divisible statute; the record established that noncitizen failed to render aid, which is a crime of moral turpitude); see Garcia-Maldonado v. Gonzales, 491 F.3d 284, 290 (5th Cir. 2007) (holding that Texas hit and run law qualifies as a CIMT, as "the failure to stop and render aid after being involved in an automobile accident is the type of base behavior that reflects moral turpitude").

Villegas-Sarabia v. Sessions, 874 F.3d 871 (5th Cir. Oct. 31, 2017) (federal conviction of misprision of a felony, in violation of 18 U.S.C. 4 ((1) knowledge that a felony was committed; (2) failure to notify the authorities of the felony; and (3) an affirmative step to conceal the felony."), was a crime against moral turpitude, because misprision of a felony required an intentional act of deceit); following Patel v. Mukasey, 526 F.3d 800 (5th Cir. April 29, 2008); Itani v. Ashcroft, 298 F.3d 1213, 1216 (11th Cir.

Saldivar v. Sessions, 877 F.3d 812 (9th Cir. Nov.

Lucio-Rayos v. Sessions, 875 F.3d 573 (10th Cir. Nov. 14, 2017) (conviction under Westminster, Colo., Municipal Code 6-3-1(A) did not categorically qualify as a crime involving moral turpitude because the statute was divisible, since one portion of the statute " demanding consideration for return of property " did not involve a permanent taking; because it was unclear from the record of conviction whether he committed a CIMT, he did not sustain his burden to prove eligibility for cancellation of removal).

NOTE: The court found that Matter of Diaz-Lizarraga, 26 I. & N. Dec.

Matter of Tavdidishvili, 27 I&N Dec. 142 (BIA 2017) (New York conviction of negligent homicide, in violation of New York Penal Law 125.10, is categorically not a crime involving moral turpitude, because it does not require that a perpetrator have any awareness of the facts that make his or her conduct dangerous.).

Escobar v. Lynch, 846 F.3d 1019 (9th Cir 2017) (California conviction of witness dissuasion, in violation of Penal Code 136.1(b)(1) is not a crime of moral turpitude).

NOTE: The Courts analysis focused on the growing rift between the BIA and the Ninth Circuit (and older BIA case law) on defining crime of moral turpitude.)

United States v. Mathis, 136 S.Ct. 894 (2016),granting certiorari in 786 F.3d 1068 (8th Cir. 2015)

The Board has frequently granted motions to reopen, sua sponte, after a conviction has been vacated. E.g., In Re: Jose Noel Meza-Perez A.K.A. Jose Noel Perez, 2011 Wl 899604 (BIA 2011) (unpublished) (The sole conviction underlying the respondent's removability under section 237(a)(2)(E)(i) of the Immigration and Nationality Act, 8 U.S.C. 1227(a)(2)(E)(i) (crime of domestic violence), has been vacated due to a defect in the criminal proceedings. The Board, therefore, will grant the respondent's motion sua sponte and terminate the proceedings.); In Re: Cesar Gomez-Rivas A.K.A.

chart at http://www.ilrc.org/files/documents/natz_chart-c-2016-3-29.pdf

Jordan v. De George, 341 U.S. 223, 231-32, 71 S. Ct. 703, 708 (1951) (We have several times held that difficulty in determining whether certain marginal offenses are within the meaning of the language under attack as vague does not automatically render a statute unconstitutional for indefiniteness. . . . Whatever else the phrase crime involving moral turpitude may mean in peripheral cases, the decided cases make it plain that crimes in which fraud was an ingredient have always been regarded as involving moral turpitude.