The Eleventh Circuit has determined that a Florida child abuse conviction, which criminalizes the battery of a child by throwing, tossing, projecting, or expelling blood, seminal fluid, urine, or feces, is both a crime of child abuse and crime involving moral turpitude.  With respect to the crime of child abuse, the Court noted that a child who has had blood or urine thrown at her by an adult is at substantial risk of mental or emotional harm, in addition to the possibility of physical injury through exposure to fluid-borne or fecal pathogens.  With respect to the crime involving moral turpitude, the Court found that the acts criminalized under the statute were base and vile.  

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

http://media.ca11.uscourts.gov/opinions/pub/files/201615898.pdf

Comment