Is making a terrorist threat a crime of moral turpitude?

Intent to do harm is not necessary for moral turpitude. A violation of Penal Code section 422, making terrorist threats, has been deemed a crime of moral turpitude. (People v. Thornton, supra, 3 Cal.App.4th 419, 424.) In Thornton, the defendant argued that since an intent to carry out the crime was not required, the crime was analogous to battery and did not necessarily involve moral turpitude. (Id. at p. 423.) The court disagreed, finding "[t]he knowing infliction of mental terror [on his victim] is equally deserving of moral condemnation." (Id. at p. 424.) The same is true of sexual battery; the degrading use of another, against her will, for one's own sexual arousal is deserving of moral condemnation. We hold that sexual battery is a crime of moral turpitude.