I. & N. Dec. at 618 (quoting Wash. Rev. Code § 9A.08.010(l)(d)). The BIA explained that, “[s]ince there was no intent required for conviction, nor any conscious disregard of a substantial and unjustifiable risk, we find no moral turpitude inherent in the statute.” Id. at 619. Virginia’s involuntary manslaughter offense is not materially different from the Washington offense. Like the assault offense underlying the Perez-Contreras decision, the ci*ime at issue here can be predicated on the offender’s failure to be aware of the risks attendant to his actions. See Perez-Contreras, 20 I. & N. Dec. at 618 (observing that criminal negligence exists when “the perpetrator ‘fails to be aware of a substantial risk’” (quoting Wash. Rev. Code § 9A.08.010(l)(d))); see also Conrad, 521 S.E.2d at 326 (<HOLDING>). As in the Perez-Contreras decision,
holding that the victims negligence is not a defense to criminal conduct recognizing that criminal negligence arises when the offender should have known the probable results of his acts holding that the subjective reason for making the arrest need not be the criminal offense as to which the known facts provide probable cause holding a duty to warn arises only when the potential victim is known and foreseeable holding that a cause of action accrues when the claimant knew or reasonably should have known of the wrong