Nunez v. Holder

California punishes persons who “willfully and lewdly ... expose [their] private parts” in a public place or in a place where there are unwilling persons. CAL. PE*1139NAL CODE § 314(1). The California Supreme Court has read § 314 to reach only one who “intentionally direct[s] attention to his genitals for sexual purposes.” In re Smith, 7 Cal.3d 362, 102 Cal.Rptr. 335, 497 P.2d 807, 810 (1972). In Gonzales v. Duenas-Alvarez, the Supreme Court told us that to find that California’s indecent exposure statute is a crime outside the generic definition of a crime involving moral turpitude “requires more…