The Fourth Circuit has determined that a Virginia conviction for obstruction of justice is not a crime involving moral turpitude because it can be committed without fraud, deception, or any other aggravating element (such as the use of threats or force) that shocks the public conscience.  In so doing, the court distinguished the statute at issue from the statute analyzed in Matter of Jurado-Delgado.

The court also clarified the requirement that a petitioner exhaust his arguments before the agency.  "[T[he Government takes issue with appellate counsel citing certain cases for the first time on appeal in order to elaborate on the breadth of the Virginia statute. The Government has not provided any basis for applying the exhaustion requirement at this level of granularity. Indeed, such an approach would strip appellate counsel’s ability to bolster existing arguments—and limit the universe of available case law and precedent to those already cited below."

The full text of Ramirez v. Sessions can be found here: