A conviction of false imprisonment, under Penal Code 236, 237, committed by menace is not a crime of moral turpitude. Turijan v. Holder, 744 F.3d 617, 621 (9th Cir. 2014). This offense also arguably does not constitute an aggravated felony crime of violence, under 18 U.S.C. 16(a), 8 U.S.C. 1101(a)(43)(F), since there is no element requiring the intentional use of violent force. Moreover, it cannot constitute an aggravated felony crime of violence under 16(b), because the Supreme Court found the ordinary case analysis to be unconstitutionally vague. See Johnson v. United States, 576 U.S. ___ (June 26, 2015). CALCRIM 1240, defining some of the elements of felony false imprisonment, provides:

Violence means using physical force that is greater than the force reasonably necessary to restrain someone.

Menace means a verbal or physical threat of harm[, including use of a deadly weapon]. The threat of harm may be express or implied.

Under the categorical analysis, the minimum conduct sufficient to convict of this offense by means of menace requires threat of harm, but not use or threat to use intentional violent force. Harm or injury is different from violent physical force. See Leocal v. Ashcroft, 543 U.S. 1 (2004).