The Second Circuit has denied a petition for review filed by a Polish lawful permanent resident convicted of conspiring to retaliate against employees who sued his construction company for wage violations, holding that the offense is categorically a crime involving moral turpitude and that the moral turpitude removability ground is not unconstitutionally vague as applied to him.
The Court held that even the least culpable conduct covered by the statute, threatening property damage in retaliation for someone's participation in official proceedings, involves both the requisite culpable intent and reprehensible conduct because it strikes at the administration of justice itself. The Court also rejected the petitioner's argument that the removability ground does not reach inchoate conspiracy offenses, and declined to revisit several other arguments already rejected in an earlier petition under the law of the case doctrine.
The full text of Dziedziach v. Blanche can be found here: https://ww3.ca2.uscourts.gov/decisions/OPN/23-6837_opn.pdf