with the very nature of the misconduct found by [New York] — a disagreement that was beyond its authority in this reciprocal matter.” Pennington, supra, 921 A.2d at 143 (citation omitted). D. Respondent’s Criminal Conviction Matter Should be Dismissed as Moot Lastly, respondent contends that he is entitled to address the Hearing Com- mittee now on the matter of whether his criminal conviction, in the United States District Court for the Northern District of Florida, involved moral turpitude — as defined in D.C.Code § ll-2503(a) We disagree. Where we impose disbarment as reciprocal discipline, we may dismiss a criminal conviction matter as moot and forego the moral turpitude inquiry. See In re Gailliard, 944 A.2d 1109, 1111-12 (D.C.2008) (citing In re Novick, 619 A.2d 514 (D.C. 1993)) (<HOLDING>). Bar Counsel recommended to the Board that we
recognizing that a court may not apply the modified categorical approach if the statute proscribes only conduct that involves moral turpitude internal quotation marks omitted holding that an intentional battery that involves the use of a deadly weapon constitutes a crime of moral turpitude holding that where a discipline proceeding involves both a criminal conviction and a reciprocal discipline matter the court may impose reciprocal discipline without engaging in a moral turpitude inquiry on the criminal conviction if the resulting discipline would be the same if a moral turpitude inquiry had been conducted recognizing the longstanding rule that crimes that have fraud as an element are categorically crimes involving moral turpitude and a court may not apply the modified categorical approach if the statute proscribes only conduct that involves moral turpitude holding that robbery under california law categorically qualified as a crime involving moral turpitude and noting precedent in this and other circuits that theft crimes are crimes involving moral turpitude