Criminal intimidation is not a CMT.  But see Stalking, § 9.28, supra.

 

United States v. Chu Kong Yin, 935 F.2d 990 (9th Cir. 1991) (criminal intimidation statute covers conduct such as “threatening to harm the reputation of a deceased person with the intent of ‘alarming’ a third person,” under Hong Kong Laws, ch. 205, § 2(b)(i), and therefore does not necessarily involve moral turpitude).

 

            Terroristic Threats may be a CMT. 

           

Chanmouny v. Ashcroft, 376 F.3d 810 (8th Cir. July 16, 2004) (Minnesota conviction for terroristic threats (“threatens, directly or indirectly, to commit any crime of violence with purpose to terrorize another . . . or in a reckless disregard of the risk of causing such terror . . . .”), in violation of Minn. Stat. § 609.713(1), was a conviction for a crime of moral turpitude, because the record of conviction established that respondent was convicted of a “purpose to terrorize,” and the Immigration Judge therefore did not err in concluding that petitioner was ineligible for suspension of deportation or voluntary departure).

 

But see Fernandez-Ruiz v. Gonzales, 468 F.3d 1159, (9th Cir. Nov. 15, 2006) (Arizona conviction in 2003 of class 2 misdemeanor domestic violence/assault, in violation of A.R.S. § § 13-1203(A), 13-3601, does not constitute a crime of moral turpitude, because the offense can be committed by "threats that cause no injury at all")

Eighth Circuit

CRIMES OF MORAL TURPITUDE " THREATS " TERRORISTIC THREATS

Ninth Circuit

CRIMES OF MORAL TURPITUDE " THREATS " CRIMINAL THREATS
Cervantes v. Holder, ___ F.3d ___, 2014 WL 6463031 (9th Cir. Nov. 19, 2014) (California conviction for threatening to commit a crime resulting in death or great bodily injury under Penal Code 422 is categorically a crime of moral turpitude, for purposes of determining whether immigrant was inadmissible under INA 212(a)(2)(A)(i)(I), 8 U.S.C. 1182(a)(2)(A)(i)(I)); following Latter"Singh v. Holder, 668 F.3d 1156, 1163 (9th Cir. 2012).

CRIMES OF MORAL TURPITUDE"THREATS"CRIMINAL THREATS
Latter-Singh v. Holder, 668 F.3d 1156 (9th Cir. Feb. 17, 2012) (California conviction of criminal threats, in violation of Penal Code 422, categorically constitutes a crime involving moral turpitude, for immigration purposes, because (1) the required threatened conduct is itself a CMT; (2) the victims must suffer sustained fear; and (3) the offense is committed with intent to instill fear), compare Fernandez"Ruiz v. Gonzales, 468 F.3d 1159, 1167 (9th Cir. 2006) (Arizona a conviction for violation of ARS 13-1203, placing another person in reasonable apprehension of imminent physical injury, is not a CMT because no intent to injure is required).