Miranda-Romero v. Lynch, ___ F.3d ___, 2015 WL 4746166 (8th Cir. Aug. 12, 2015) (California conviction of forgery, under Penal Code 472, categorically constitutes crime of moral turpitude, since entire statute requires intent to defraud).

Note: This decision is erroneous. The plain language of the statute includes three groups of offenses, of which only the first expressly requires intent to defraud. The Eighth Circuit relies on California decisions discussing the statute as a whole, which do not consider whether there is a different mental element for each of the three groups of offenses stated in the disjunctive. In particular, the third group of offenses, penalizing one who has in his possession any such [fraudulently] counterfeited seal or impression thereof, knowing it to be counterfeited, and willfully conceals the same, is guilty of forgery, is innocent of an intent to defraud under the plain language of the statute. It is doubtful that most Ninth Circuit panels would agree with this sloppy decision.