Escobar v. Lynch, 846 F.3d 1019 (9th Cir 2017) (California conviction of witness dissuasion, in violation of Penal Code 136.1(b)(1) is not a crime of moral turpitude).

NOTE: The Courts analysis focused on the growing rift between the BIA and the Ninth Circuit (and older BIA case law) on defining crime of moral turpitude.)