The Ninth Circuit has determined that a Hawaii conviction for fourth degree theft is not a crime involving moral turpitude because it does not require the defendant to intend to permanently deprive or substantially erode the owner’s property interests. The court further determined that the statute is indivisible.

The full text of Maie v. Garland can be found here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2021/08/02/19-73099.pdf

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