The Ninth Circuit has determined that Idaho's petit theft statute is overbroad as compared to the definition of a crime involving moral turpitude because it criminalizes temporary takings of property.  

The court also noted that the effect of an inconclusive record is unclear because it remains an open question whether the burden allocations in Young v. Holder survived the Supreme Court's decision in Moncrieffe v. Holder.  However, the panel declined to reach that question because another panel has priority to do so.  

The court also directed the BIA to reconsider its decision in Matter of Cortez, in which the BIA found that the unambiguous text of the cancellation statute disqualified any person from seeking cancellation who had been convicted of a crime involving moral turpitude for which a sentence of at least one year could be imposed, regardless of whether the conviction took place more than five years after the person's admission to the United States.  The court found the statute is not unambiguous, and thus, directed the BIA to examine its analysis using its discretion to interpret the statute in a reasonable manner. 

The full text of Lozano-Arredondo v. Sessions can be found here: