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United States Ninth Circuit


Espino-Castillo v. Holder, 13-70756

Petition for review of a decision by the Board of Immigration Appeals finding that petitioner’s state law forgery conviction qualified as a crime involving moral turpitude, and ordering removal, is denied, where: 1) petitioner’s conviction under Arizona Revised Statutes section 13-2002 qualifies a categorical crime involving moral turpitude because the statute criminalizes conduct that constitutes fraud; and 2) the exception established in Beltran-Tirade v. INS has never been applied outside the social security context, and here, the underlying conduct involved the use of false information to obtain employment.

Appellate Information

  • Decided 10/29/2014
  • Published 10/29/2014

Judges

  • Schroeder

Court

  • United States Ninth Circuit

Counsel

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