The Fifth Circuit has denied a petition for review filed by a Nigerian lawful permanent resident found inadmissible for a prior conviction for using a forged passport, holding that knowing use of a false or invalidated passport is categorically a crime involving moral turpitude.
No longer deferring to the BIA under Loper Bright, the Court independently held that using a document known to be false, or a once-valid passport known to have become void, involves the kind of fraud or deceit against the issuing government that has long defined moral turpitude, regardless of whether the specific conduct involved forgery or merely continued use of an invalidated document.
The full text of Ademola v. Blanche can be found here: https://www.ca5.uscourts.gov/opinions/pub/25/25-60475-CV0.pdf