The Third Circuit has determined that a Pennsylvania conviction for making terroristic threats - which criminalizes communicating, either directly or indirectly, a threat to commit any crime of violence with intent to terrorize another - is categorically a crime involving moral turpitude.  The petitioner argued that “crime of violence” encompasses simple assault, and as such, the statute criminalizes threatening to commit a simple assault (a non-turpitudinous crime).  The court rejected his argument, finding that the requirement of a specific intent to terrorize differentiated the statute from simple assault, and that such an intent demonstrates that the defendant acted with a vicious motive or corrupt mind.

The full text of Javier v. Attorney General can be found here: