Penuliar v. Ashcroft, ___ F.3d ___, 2005 WL 74093 (9th Cir. January 12, 2005) (California conviction of unlawful driving or taking a vehicle, in violation of Vehicle Code 10851(a), was not a theft offense, within the meaning of INA 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G), because the statute and charge both were overbroad with respect to the definition of a theft offense by encompassing not only substantive theft offenses but aiding and abetting them as well).
http://caselaw.lp.findlaw.com/data2/circs/9th/0371578p.pdf