The Ninth Circuit has concluded that a California conviction for stalking is categorically a crime involving moral turpitude. The court noted that the statute requires a willful course of conduct that puts a person in reasonable fear for their safety. It also requires the defendant to have made a credible threat of harm. The court also concluded that the petitioner’s two stalking convictions, which related to conduct on different dates, did not arise of a single criminal scheme.

The full text of Orellana v. Barr can be found here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2020/07/28/19-70164.pdf

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