Morales-Garcia v. Holder, 567 F.3d 1058 (9th Cir. 2009) (California conviction of corporal injury of a spouse, in violation of Penal Code 273.5(a), did not categorically constitute a crime involving moral turpitude, because it includes victims other than a spouse); distinguishing Grageda v. INS, 12 F.3d 919 (9th Cir. 1993) (California conviction of corporal injury of a spouse, in violation of Penal Code 273.5(a), constituted a crime involving moral turpitude under the modified categorical analysis where the record of conviction established that the victim was the defendants spouse); Matter of Tran, 21 I. & N. Dec. 291 (BIA 1996) (same).

jurisdiction: 
Ninth Circuit

 

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