Crimes of Moral Turpitude

Criminal intimidation is not a CMT.  But see Stalking, § 9.28, supra.

United States v. Chu Kong Yin, 935 F.2d 990 (9th Cir. 1991) (criminal intimidation statute covers conduct such as “threatening to harm the reputation of a deceased person with the intent of ‘alarming’ a third person,” under Hong Kong Laws, ch. 205, § 2(b)(i), and therefore does not necessarily involve moral turpitude).

            Terroristic Threats may be a CMT. 

Chanmouny v. Ashcroft, 376 F.3d 810 (8th Cir. July 16, 2004) (Minnesota conviction for terroristic threats (“threatens, directly or indirectly, to commit any crime of violence with purpose to terrorize another . . . or in a reckless disregard of the risk of causing such terror . . . .”), in violation of Minn. Stat. § 609.713(1), was a conviction for a crime of moral turpitude, because the record of conviction established that respondent was convicted of a “purpose to terrorize,” and the Immigration Judge therefore did not err in concluding that petitioner was ineligible for suspension of deportation or voluntary departure).

But see Fernandez-Ruiz v. Gonzales, 468 F.3d 1159, (9th Cir. Nov. 15, 2006) (Arizona conviction in 2003 of class 2 misdemeanor domestic violence/assault, in violation of A.R.S. § § 13-1203(A), 13-3601, does not constitute a crime of moral turpitude, because the offense can be committed by "threats that cause no injury at all")