Mohamed v. Holder, 769 F.3d 885 (4th Cir. 2014)
Nature of Case: Petitioner, a lawful permanent resident, was ordered removed by the Board of Immigration Appeals on the grounds that he was convicted of two offenses which were characterized as crimes involving moral turpitude and thus made him removable. Petitioner contended that one of these offenses, failure to register as a sex offender, was not a crime involving moral turpitude, and thus he was not removable. Board rejected this argument, and Petitioner sought review.
Holding: Fourth Circuit Court of Appeals held that failure to register as a sex offender did not constitute a crime involving moral turpitude for immigration purposes. The Court noted that, even even sex offense registration regimes constituted laws that were important for public policy reasons, the act of failing to register did not — in and of itself — constitute a separate violation of a moral norm so as to constitute a crime involving moral turpitude. Reversed.