The Ninth Circuit has denied a petition for review filed by a lawful permanent resident removable for a conviction under Oregon's statute criminalizing using a child in a display of sexually explicit content, holding the offense is categorically a crime of child abuse under the same framework applied the same day in a companion California case.
The Court held Oregon courts have consistently required a mens rea of intent or knowledge for the offense, and that the actus reus categorically creates a likelihood of physical or emotional harm to the child regardless of the age gap between defendant and victim or whether physical touching occurred, distinguishing the petitioner's reliance on a narrower California statute previously found not to qualify.
The full text of Gonzalez-Godinez v. Blanche can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/08/10/19-71322.pdf