What is the current state of the law on deportable status of an alien convicted of multiple crimes of moral turpitude?

to an important exceptionnamely, that an alien is deportable only if he or she is convicted of two crimes of moral turpitude "not arising out of a single scheme of criminal misconduct ." Id . (emphasis added). Thus, while the multiple convictions could now occur at a single trial, the proviso that they could not arise out of a single scheme of criminal misconduct meant that the amended statutory language retained, albeit in a narrower form, the prior statutes comparable focus on repeat criminals who had demonstrated "lawless propensities." Costello v. INS , 376 U.S. 120, 134, 84 S.Ct. 580, 11 L.Ed.2d 559 (1964) (White, J., dissenting).