For those who follow the crimmigration trends in the Ninth Circuit, there was great hope that last year's decision in Ceron v. Holder (finding that assault with a deadly weapon under section 245(a)(1) of the California Penal Code was not categorically a crime involving moral turpitude) would also lead to new case law finding that a conviction under this statute does not qualify as a crime of violence.  Alas, the Ninth Circuit, in a brief criminal sentencing decision yesterday, dashed our hopes.  The court followed its past precedent on the issue, and found that Ceron did not impact that precedent.


The full decision in United States v. Jiminez-Arzate can be found here: