The Ninth Circuit has determined that an Oregon conviction for menacing constituting domestic violence is not a crime involving moral turpitude because it does not require the actual infliction of fear. “A CIMT determination requires both an evil or malicious intent and the infliction of actual substantial harm on another. In Latter-Singh, we explained that the injury required under § 422—that the victim experience sustained fear from the threat—ensured that the statute criminalized only ‘conduct which results in substantial harm’ and excluded non-turpitudinous conduct such as ‘emotional outbursts’ or ‘mere angry utterances or ranting soliloquies, however violent.’” “The Oregon menacing statute prohibits words or conduct that is intended to place others in fear of imminent serious physical injury, but it does not require any intent to cause injury or that the victim experience any actual fear or injury as a result of the criminal act.”
The full text of Flores-Vasquez v. Garland can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2023/08/31/20-73447.pdf