The Ninth Circuit determined that a conviction in California for perjury is not necessarily a crime involving moral turpitude (CIMT). The court recognized that common law perjury has long been considered a CIMT, but noted that California's definition of perjury was much broader, encompassing lies told outside of a judicial proceeding, as well as lies made where no oral oath of honesty was required. The court also observed that the fact that one need not be competent to give the false statement demonstrates that not all convictions result from evil or malicious intent. Similarly, the fact that lack of knowledge as to the false statement’s materiality is not a defense to conviction further demonstrates that not all conduct covered by the statue involves an intent to harm someone. Perjury does not necessarily involve intent to harm, actual infliction of harm, or an action that affects a protected class of victim, nor does it include a specific intent to defraud.
The court also determined that California's perjury statute is divisible, encompassing two separate crimes: written perjury and oral perjury. The court concluded that written perjury is not a CIMT.
The full text of Rosales Rivera v. Lynch can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2016/03/10/12-72668.pdf