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ourt Says Arizona Fraud Conviction Involving Employment Application Is a CIMT


The Ninth Circuit held that the petitioner’s conviction under Arizona Revised Statutes §13-2002 is a crime involving moral turpitude (CIMT) because the statute criminalizes conduct that constitutes fraud. The panel held that the exception in Beltran-Tirado to the clearly established rule that a fraud conviction is a CIMT did not apply to this offense, where the underlying conduct involved the use of false information to obtain employment.

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