The Ninth Circuit has determined that 18 U.S.C. § 2320 (trafficking in counterfeit goods) is not an aggravated felony involving fraud or deceit because a conviction can rest upon conduct that is merely like to cause confusion or mistake, and does not necessarily require any intent to deceive another person. Thus, the District Court erred in finding that the applicant was not eligible for naturalization as person lacking in good moral character. The Court also suggested that a conviction under this statute would not qualify as a crime involving moral turpitude, and suggested that past precedent interpreting the immigration consequences of California's counterfeit goods statute may no longer be good law.
The full text of Wang v. Rodriguez can be found here: