On April 9, the Ninth Circuit Court of Appeals issued a published decision involving crimes involving moral turpitude in the immigration context, in a case where Western State College of Law at Argosy University Professor Jennifer Koh served as amicus counsel (along with Professor Kari Hong at Boston College Law School) on behalf of law professors and clinicians with expertise in immigration law or experience defending noncitizens in immigration proceedings. The case, Garcia-Martinez v. Sessions, involved the scope of theft crimes and the immigration law definition of a crime involving moral turpitude, and held that an expanded definition of crimes involving moral turpitude could not retroactively apply to certain theft crimes. Judge Ferdinand Fernandez wrote the opinion.