Planes v. Holder, ___ F.3d ___, ___, 2011 WL 2619105 (9th Cir. Jul. 5, 2011) (Accordingly, nothing in Navarro"Lopez disturbs the longstanding rule that crimes that have fraud as an element, such as Planes's convictions at issue here, are categorically crimes involving moral turpitude.); citing Navarro"Lopez v. Gonzales, 503 F.3d 1063, 1074 (9th Cir.2007) (en banc).