Safe Havens

(B)  Crimes of Moral Turpitude.

Counterfeiting and passing of counterfeit currency or obligations of the United States are generally regarded as crimes involving moral turpitude.[56]  Moral turpitude has been found in all cases involving offenses against the government or its authority where intent to inflict economic loss on the government is an element. 

Counterfeiting coins, however, has been held NOT to be a crime involving moral turpitude. 

Board of Immigration Appeals:

Matter of Lethbridge, 11 I. & N. Dec. 444, 445 (BIA 1965) (conviction under that portion of 18 U.S.C. § 474 which makes it a crime to possess securities made after the similitude of United States securities intending to sell and use them, is not a conviction of a crime involving moral turpitude: “Language in the indictment charging knowledge of the counterfeit nature of the securities is not found in 18 U.S.C. § 474 and would therefore appear to be surplusage”).

Matter of K, 7 I. & N. Dec. 178 (BIA 1956) (passing or possession counterfeit coins, under prior 18 U.S.C. § 227 (now 18 U.S.C. § 485), is not a crime of moral turpitude), overruled on other grounds by Matter of Flores, 17 I. & N. Dec. 225 (BIA 1980).

Matter of G, 2 I. & N. Dec. 235 (BIA 1945) (depositing a metal disc instead of a nickel in a subway turnstile in violation of New York Penal Law § 1293(c) held not to involve moral turpitude, since the statute violated did not require criminal intent or even knowledge on the part of the wrongdoer, overruling earlier decisions to the effect that this crime involved moral turpitude, since accidental or inadvertent use of a slug or counterfeit coin could possibly be the basis of a conviction under this statute).

Seventh Circuit:

United States ex rel. Giglio v. Neelly, 208 F.2d 337, 341 (7th Cir. 1954) (convictions for violating 18 U.S.C. § 282 (1946), counterfeiting nickels, held not to involve moral turpitude).

[56] See N. Tooby, J. Rollin & J. Foster, Crimes of Moral Turpitude § 9.33 (2005).