The Seventh Circuit has determined that retroactive application of Matter of Thomas & Thompson to sentencing modifications entered before the issuance of the decision would be impermissible. The decision, however, was entitled to deference as applied to more recent sentence modifications.
The court also determined that an Indiana conviction for neglect of a dependent is a crime involving moral turpitude. The statute requires intentional or knowing conduct, namely confinement which is likely to result in a harm such as disfigurement, mental distress, extreme pain or hurt, or gross degradation, and yet does not necessarily endanger the dependent’s life or health.
The full text of Zaragoza v. Garland can be found here: