Turijan v. Holder, 744 F.3d 617 (9th Cir. Mar. 10, 2014) (California conviction of felony false imprisonment, in violation of Penal Code 236, 237 [deprivation of liberty of another by violence or menace], was not a categorical crime of moral turpitude, because it does not require the intent to injure, actual injury, or a protected class of victim, and California courts have applied the statute to conduct that is not morally turpitudinous); following Castrijon"Garcia v. Holder, 704 F.3d 1205, 1218 (9th Cir. 2013) (California conviction of simple kidnapping under Penal Code 207(a) is not categorically a crime of moral turpitude).

 

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