The Eighth Circuit has determined that a conviction for first degree assault in Arkansas is categorically a crime involving moral turpitude.  A conviction for first degree assault requires recklessly engaging in conduct that creates a substantial risk of death or serious physical injury to another person.  The court agreed with the Board of Immigration Appeals that such conduct is "contrary to the accepted and customary rule of right and duty between man and man."

The full text of Estrada-Rodriguez v. Lynch can be found here: