Uppal v. Holder, 576 F.3d 1014 (9th Cir. Aug. 11, 2009) (BIA's determination a conviction qualifies as a crime of moral turpitude is entitled to Skidmore deference: "The measure of deference due to the BIA's decision under Skidmore
varies 'depending upon the thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it the power to persuade, if lacking power to control.' Skidmore, 323 U.S. at 140."); citing Marmolejo-Campos, 558 F.3d at 911.