Crimes of Moral Turpitude should be analyzed under 24 I & N DEC 687 (2008). Step 1: – If it is clearly a CMT then the analysis is over; Step 2: Was there a temporary or permanent taking; Step 3: What extrinsic evidence exists (this can be shown); Step 4 – CMT is a non elemental fact. Look at Johnso vs. US (130 S.Ct. 1265 (2010)) or Matter of Milan – 25 De. 197 (BIA 2010).
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Brian D. Lerner Immigration Attorney & Deportation Lawyer Blog 
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