Ferreira v. Ashcroft, 390 F.3d 1091 (9th Cir. Dec. 1, 2004) (California welfare fraud offense, defined in Welf. & Inst. Code 10980(c)(2), is a divisible statute with respect to the requirement of loss to the victim in excess of $10,000, for purposes of qualifying as an aggravated felony as defined under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), since it penalizes losses in excess of $400, as opposed to $10,000, and modified categorical analysis is required to determine whether the record of conviction, including the plea agreement and amount of restitution, of the particular conviction establish a loss in excess of $10,000).