United States v. Pallares-Galan, 359 F.3d 1088 (9th Cir. February 20, 2004) (California Penal Code 647.6(a), annoy or molest a child under 18, is a divisible statute, and does not constitute an aggravated felony "sexual abuse of a minor" offense).
http://caselaw.lp.findlaw.com/data2/circs/9th/0210532p.pdf Under the categorical approach, California Penal Code 647.6(a) covers conduct which is and which is not "sexual abuse of a minor." Where the record of conviction does not show "sexual abuse of a minor" the conviction is not an aggravated felony. Therefore, the key to avoiding an aggravated felony is a sanitized record of conviction.
jurisdiction:
Ninth Circuit