The Eleventh Circuit has determined that a Florida conviction for abuse of an elderly or disabled person is categorically a crime involving moral turpitude.  The court acknowledged that no actual injury need be inflicted on the victim, and that the statute can be violated by encouraging another person to abuse the victim.  Nonetheless, the court focused on the vulnerable population protected by the statute to find that all conduct criminalized under the statute involves moral turpitude.

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