Parrilla v. Gonzales, ___ F.3d ___, 2005 WL 1606506 (July 11, 2005) (Washington conviction of communication with a minor for immoral purposes, in violation of Washington Revised Code section 9.68A.090, was not on its fact an aggravated felony because it did not categorically meet the definition of "sexual abuse of a minor" under INA 101(a)(43)(A), 8 U.S.C. 1101(a)(43)(A), because the statute broadly included "immoral purposes" such as providing information on how to get an unlawful abortion, displaying pornography visible from a public thoroughfare, and allowing a minor onto the premises of a live erotic performance, which, while not commendable, were not abusive in nature), citing Pallares-Galan, 359 F.3d at 1101-02.
http://caselaw.lp.findlaw.com/data2/circs/9th/0374010p.pdf

     The case arose because Parrilla was denied eligibility to apply for "LPR Cancellation of Removal" as an aggravated felon. However, if his plea had been done differently, Parrilla might not even have been deportable. Even though CMIP constitutes a "crime involving moral tupitude (CIMT)," a ground distinct from SAM, long-term residents are not always deportable for a single CIMT.  Assuming Parrilla stands, Communication with a Minor For Immoral Purposes could be a safer alternative plea to more serious sex offenses that would be aggravated felonies as either "rape" or "sexual abuse of a minor."  This disposition will be safe, however, if (and only if) the record of conviction, including the information, judgment and sentence, and plea statement, is limited to the language of the statute and does not establish that the immoral purpose of the communication was to commit a specific offense that would be considered rape or sexual abuse of a minor.