Decision date: 2017-01-24

Holding that Virginia involuntary manslaughter under Va. Code § 18.2-36 is not a crime involving moral turpitude (CIMT) because it requires only failure to perceive risk (criminal negligence) rather than conscious disregard of risk (gross negligence). 

Publication Status: Published

Case judge: Agee, King, Niemeyer

Decision: Sotnikau v. Lynch, 846 F.3d 731 (4th Cir. 2017)