CA9 Upholds Matter of Leal (Categorical CIMT)

Court Staff Summary: "The panel denied Edgar Leal’s petition for review of the three-judge published Board of Immigration Appeals’ decision, Matter of Leal, 26 I. & N. Dec. 20 (BIA 2012), which held that Leal’s conviction for felony endangerment, in violation of Arizona Revised Statute § 13-1201, is a categorical crime involving moral turpitude.  The panel held that the BIA reasonably determined that ARS § 13-1201 is a crime involving moral turpitude, and the panel accordingly gave Chevron deference to the BIA’s decision.  The panel also held that the BIA reasonably determined that excessive voluntary intoxication, combined with the creation of a substantial, actual risk of imminent death of another person, constitutes morally turpitudinous conduct." - Leal v. Holder, Nov. 6, 2014.