Galeana-Mendoza v. Gonzales, 465 F.3d 1054, 2006 WL 2846379 (9th Cir. Oct. 6, 2006) (California convictions of simple battery on the mother of defendant's child, in violation of Penal Code 243(e)(1), were not categorically crimes of moral turpitude since the least touching was sufficient to violate the statute, and the domestic relationship, standing alone, was insufficient to establish moral turpitude).