Moises Arias & Willow Smith Pic In Bed -- Creepy... But NOT Criminal

This photo -- showing 13-year-old Willow Smith posing in bed with 20-year-old Disney star Moises Arias -- is creepy, but not criminal ... according to multiple law enforcement sources.

The pic has made the rounds and lots of people think it crosses the line -- even the legal line. But TMZ contacted sources at the L.A. County Sheriff's Dept. (which covers the area where Willow lives) and the Indio P.D. (which covers the area where the pic was snapped) ... and our sources were clear ... there's nothing "sexual enough" to raise police eyebrows.

Our sources say no one has called either department to complain.

So creepy, but not criminal.