Efstathiadis v. Holder, 752 F.3d 591 (2d Cir. May 20, 2014) (Connecticut conviction of sexual assault, in violation of Connecticut General Statute 53a73a(a)(2), may or may not be a crime of moral turpitude, depending on (1) whether it is a strict liability offense with respect to the lack of consent element, and (2) if not, what level of mens rea visvis that element is required to support a conviction; We conclude only that in the context of a conviction arising under C.G.S. 53a"73a(a)(2), where the only factors affecting the moral character of the crime are the intention to receive sexual gratification (or to humiliate) and the mens rea associated with lack of consent, strict liability as to lack of consent would not lend support to categorization as a CIMT .; the court certified the question of what mens rea is attached to consent element of the statute to the Connecticut Supreme Court).

NOTE: The court specifically held that intent to receive sexual gratification, standing alone, is not evil. Efstathiadis v. Holder, 752 F.3d 591, 597 (2d Cir. May 20, 2014).