Ghani v. Holder, 557 F.3d 836 (7th Cir. Mar. 9, 2009) (federal conviction for making a false statement to an officer, in violation of 18 U.S.C. 1001, is categorically a crime involving moral turpitude; "Even if the conduct for which Mr. Ghani was convicted did not rise to the level of fraud, however, his conviction necessarily establishes that he knowingly and willfully lied to the Government of the United States about a material matter.") NOTE: In the Seventh Circuit, Ali v. Mukasey, 521 F.3d 737 (7th Cir. 2008) applied Matter of Babaisakov, 24 I. & N. Dec. 306 (BIA 2007), and resulted in the A.G.s new analytical model in Matter of Silva-Trevino, 24 I. & N. Dec. 687 (A.G. Nov. 9, 2008). The court in this case did not explain how it was determining whether the conviction was a CMT (i.e, under Taylor or Silva-Trevino). The Courts statement that a violation of 18 U.S.C. 1001 is a CMT regardless of the defendants underlying conduct seems to establish that the new fact-based analysis only runs one way. This is arguably unconstitutional. See Wardius v. Oregon, 412 U.S. 470 (1973) (due process requires procedural rules to be even-handed in their application, striking down a state law requiring the defendant to produce discovery for the prosecution, but not vice versa). Due process also prohibits a tribunal from allowing one party to offer evidence on an issue, but precluding the other party from doing so. Green v. Georgia, 442 U.S. 95, 97, 99 S.Ct. 2150, 60 L.Ed.2d 738 (1979) (per curiam) (reversing sentence because trial court excluded testimony offered by the defense under Georgia's hearsay rules, but allowed the prosecution to introduce the same evidence in a codefendant's trial); Gray v. Klauser, 282 F.3d 633, 644 (9th Cir. 2002) (Idaho deprived petitioner of right to present a defense under Sixth Amendment when trial court used different standard for determining admissibility of hearsay statements from two dead victims. "A state rule or state judge may not without justification impose stricter evidentiary standards on a defendant . . . than it does on the prosecution.").