The Board of Immigration Appeals (BIA) has determined that a Minnesota conviction for making terroristic threats is a crime involving moral turpitude. In so doing, the BIA noted that the statute requires intentionally “caus[ing] extreme fear by use of violence or threats.” “First, we conclude that the communication of an intent to injure another by use of violence involves sufficiently reprehensible conduct to constitute a crime involving moral turpitude.” “In this regard, we clarify that making a threat to commit a crime of violence in violation of Minnesota’s terroristic threats statute is a crime involving moral turpitude, even if the threatened crime would not necessarily qualify as a crime involving moral turpitude.” “We note that the Minnesota statute requires either evacuation or ‘serious’ public inconvenience, which ensures that threats resulting in minor societal interference are not criminalized. Indeed, our review of Minnesota case law indicates that convictions that could fall under this prong of this statute involve, at minimum, reckless disregard that deployment of significant public resources would result from the violators’ actions.”
The full text of Matter of Salad can be found here:
https://www.justice.gov/eoir/page/file/1231366/download