Sara Salem


Although absent from modern English conversation, the words moral turpitude continue to carry devastating consequences for undocumented aliens living in the United States. Under federal immigration law, an alien convicted of a crime involving moral turpitude may be deported or denied entry into the United States. Perhaps most significantly, nearly all immigration relief is conditioned on an alien having never been convicted of a crime involving moral turpitude. So the question becomes, what is a crime involving moral turpitude? There is currently no clear answer. No one standard exists for determining whether a conviction qualifies as a crime involving moral turpitude. Circuit courts are split, each applying their own body of case law to determine issues of moral turpitude that reach their dockets. This Note reviews the history and inconsistencies of CIMT jurisprudence, explains Attorney General Mukasey’s failed attempt to standardize the area, and finally recommends a standard approach to be applied by the BIA and circuit courts across the country.