Ninth Circuit on CIMT, Cal. Penal Code § 422: Latter-Singh v. Holder

"Singh claims that the BIA wrongly determined that a violation of California Penal Code § 422 constitutes a crime involving moral turpitude (or “CIMT”), thus rendering him removable. Although we previously determined that a violation of § 422 is an aggravated felony, see Rosales-Rosales v. Ashcroft, 347 F.3d 714, 717 (9th Cir. 2003), we have not yet decided whether § 422 is categorically a crime involving moral turpitude. We do so now and answer the question in the affirmative." - Latter-Singh v. Holder, Feb. 17, 2012.