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 E.g., In Re: Jose Noel Meza-Perez A.K.A. Jose Noel Perez, 2011 Wl 899604 (BIA 2011) (unpublished) (The sole conviction underlying the respondent's removability under section 237(a)(2)(E)(i) of the Immigration and Nationality Act, 8 U.S.C. 1227(a)(2)(E)(i)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.

Alonzo v. Lynch,___ F.3d ___, 2016 WL 1612772 (8th Cir. Apr. 22, 2016) (Iowa convictions for domestic abuse assault, third or subsequent offense, in violation of Iowa Code Annotated 708.1, a divisible statute, did not categorically constitute crimes of moral turpitude, since a single conviction of that offense is not necessarily a crime of moral turpitude). See Cisneros"Guerrerro v. Holder, 774 F.3d 1056, 1061 (5th Cir. 2014).

Note: The court noted, but made no decision on, the issue of whether conviction of multiple non-CMT offenses can arise to the level of a CMT.

Alonzo v. Lynch,___ F.3d ___, ___, 2016 WL 1612772 (8th Cir. Apr. 22, 2016) ([T]he BIA and various courts have declined to classify [simple assault] as a [CIMT]. Simple assault typically is a general intent crime, and it is thus different in character from those offenses that involve a vicious motive, corrupt mind, or evil intent. Chanmouny v. Ashcroft, 376 F.3d 810, 814"15 (8th Cir. 2004) (emphasis added) (quoting Matter of O, 3 I. & N. Dec. 193, 194"95 (BIA 1948)); see also [Matter of] Solon, 24 I. & N. Dec. at 241 (same).).

Sauceda v. Lynch, ___ F.3d ___ (1st Cir. Apr.

Mancilla-Delafuente v. Lynch, 804 F.3d 1262 (9th Cir. Nov. 2, 2015) (Nevada conviction for conspiracy to possess credit card without cardholder's consent, in violation of NRSA 199.480, 205.690(2) (possess[ion of] a credit card or debit card without the consent of the cardholder and with the intent to circulate, use, sell or transfer the credit card or debit card with the intent to defraud.), required intent to defraud and was therefore a crime involving moral turpitude); see Matter of Cortez, 25 I. & N. Dec.

Matter of Chairez and Sama, 26 I. & N. Dec. 686 (A.G. 2015) (referred to Atty Gen. for review of issues relating to the application of Descamps v. United States, 133 S. Ct. 2276 (2013); ordering cases stayed and not regarded as precedential during pendency of review).