Matter of Raul ZARAGOZA-VAQUERO, 26 I&N Dec. 814 (BIA Sep. 23, 2016).
The Board of Immigration Appeals holds that that the offense of criminal copyright infringement relating to the sale of infringing CDs is a crime involving "moral turpitude," and therefore the felon respondent was unable to establish that he was eligible for cancellation of removal. In other words, the individual was subject to being deported based upon his criminal conviction for copyright infringement. The Court noted that criminal liability requires willfulness, unlike civil liability under the Copyright Act, and that that criminal copyright infringement is closely
analogous to the theft and fraud crimes that the Court had consistently held are crimes involving moral turpitude.