Reyes-Morales v. Ashcroft, ___ F.3d ___ (8th Cir. Jan. 31, 2006) (Minnesota conviction for making harassing phone calls, under Minn.Stat. 609.749, is not a crime involving moral turpitude because it does not require intentional transmission of threats: "Reyes-Morales was convicted of intentionally making telephone calls with reason to know that such calls would cause, and did cause, the recipient to feel frightened. A reckless mental state, without more, typically does not give rise to a finding of moral turpitude. See In re Fualaau, 21 I. & N. Dec. at 478 (noting that although the BIA has "issued precedents holding that a conviction involving reckless conduct" can provide the basis for a finding of moral turpitude, the alien's reckless conduct is typically coupled with an aggravating factor).").
http://caselaw.lp.findlaw.com/data2/circs/8th/051008p.pdf