The Ninth Circuit has determined that a conviction under section 114 of the California Penal Code is neither a crime involving moral turpitude nor an aggravated felony. With respect to the aggravated felony issue, the court noted that the statute the California statute cannot be a match to the federal offense it includes documents, such as fake drivers’ licenses, that are not enumerated in the aggravated felony definition. With respect to the crime involving moral turpitude issue, the court noted that the statute of conviction “ does not require that there be any specific benefit to any specific person—it permits conviction simply for the use of a document to show another that the holder is a legal resident, even where that representation does not incur any benefit to the defendant.”
The full text of Jauregui-Cardenas v. Barr can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2020/01/13/16-71309.pdf