Ninth Circuit

CRIME OF MORAL TURPITUDE - FAILURE TO REGISTER AS A SEX OFFENDER NOT CMT
Plasencia-Ayala v. Mukasey, 516 F.3d 738 (9th Cir. Feb. 7, 2008) (Nevada conviction of failure to register as a sex offender, in violation of Nev. Rev. Stat. 179D.550, does not constitute a crime involving moral turpitude within the meaning of INA 237(a)(2)(A)(i)(I), 8 U.S.C. 1227(a)(2)(A)(i)(I), because the offense of conviction is a strict liability offense without any intent requirement), following Quintero-Salazar v. Keisler, 506 F.3d 688, 693 (9th Cir. 2007); Mei v. Ashcroft, 393 F.3d 737, 740 (7th Cir. 2004) ("crimes deemed not to involve moral turpitude ... are either very minor crimes that are deliberate or graver crimes committed without a bad intent, most clearly strict-liability crimes"), disagreeing with Matter of re Tobar-Lobo, 24 I. & N. Dec. 143 (BIA April 23, 2007) (California conviction of willful failure to register by a sex offender who has been previously apprised of the obligation to register, in violation of Penal Code 290(g)(1), is a crime involving moral turpitude).