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Got a theft offense. Think your an aggravated felon? Think again.


The Ninth Circuit granted the petition for review and remanded, finding that a conviction under California’s theft statute is categorically not a theft offense, and thus not an aggravated felony, because the statute is both overbroad and indivisible, and such a conviction is not susceptible to the modified categorical approach pursuant to Descamps v. United States and Rendon v. Holder.

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