The Ninth Circuit Court of Appeals in Duran v. Lynch, No. 12-70930 (9th Cir. Jan. 20, 2017) was asked to determine whether California Penal Code § 136.1(a), witness tampering, is categorically a crime involving moral turpitude. Duran entered the U.S. in 1989, fleeing violence in El Salvador, and applied for asylum ten years later. After the asylum denial, she was served with a Notice to Appear. In immigration proceedings, she applied for cancellation of removal under 8 U.S.C