The Ninth Circuit has denied a petition for review filed by a lawful permanent resident found ineligible for cancellation of removal based on a conviction for distributing harmful matter to a minor for purposes of seduction, holding the offense categorically qualifies as a crime of child abuse under the framework recently announced in Leon-Briviesca v. Blanche.
The Court rejected each of the petitioner's overbreadth arguments, holding that California law treats such conduct as inherently harmful to minors regardless of actual injury, that the statute's "harmful matter" requirement forecloses any realistic probability of prosecuting purely consensual communications between older minors, and that the petitioner identified no realistic probability the statute is applied where the purported minor victim is actually an adult or never received the communication.
The full text of Adame Garcia v. Blanche can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/08/10/16-71147.pdf