Penuliar v.
Ashcroft, 395 F.3d 1037 (9th Cir. Jan. 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 both the statute and charge were overbroad with respect
to the definition of a theft offense because they encompassed
not only substantive theft offenses but aiding and abetting
them as well).