The Ninth Circuit has held that a conviction under section 136.1(a) of the California Penal Code (witness tampering) is not categorically a crime involving moral turpitude.  The court noted that "the statute does not require the intent to 'injure someone, an actual injury, or a protected class of victims,' such as children."  In addition, it "does not require that an individual make false statements nor procure anything of value," and as such, is not a fraud-type crime involving moral turpitude.  The court remanded the case to the Board of Immigration Appeals to determine in the first instance if the statute is divisible.

The full text of Duran v. Lynch can be found here: