Penal Code 186.22(d), committing a felony or misdemeanor for the benefit of a criminal street gang, is not a crime of moral turpitude. The minimum conduct sufficient to commit this offense would be committing a crime, the least serious of which would be vandalism, in violation of Penal Code 594, in association with members of a criminal street gang with knowledge that its members engage in criminal conduct. Vandalism, aka malicious mischief, however, is not a crime of moral turpitude. Rodriguez-Herrera v. INS, 52 F.3d 238 (9th Cir. 1995). Therefore, committing this offense for the benefit of a street gang is not a crime involving moral turpitude. See Matter of Rivens, 25 I. & N. Dec. 623 (BIA Oct. 19, 2011) (accessory after the fact is not a moral turpitude offense unless the principals crime is a moral turpitude offense). See also Robert L. v. Superior Court, 30 Cal. 4th 894 (June 5, 2003)(Penal Code 186.22(d) applies to all felonies and all misdemeanors, allowing for an alternative greater punishment for misdemeanors).