Immigration counsel can argue that a person convicted of aiding and abetting the commission of a deportable offense is not deportable unless the definition of aiding and abetting, under the law of the jurisdiction of conviction, is coextensive with the federal definition of aiding and abetting. For example, in California, a person can be convicted of aiding and abetting on the basis of mere encouragement, even if no actual assistance is provided. This form of aiding a theft offense has been held insufficient to constitute a theft offense aggravated felony. United States v. Corona-Sanchez, 291 F.3d 1201 (9th Cir. 2002) (en banc). This same argument could be used to argue that a conviction of aiding and abetting any other deportable offense - a firearms conviction, crime of moral turpitude, domestic violence conviction, or controlled substances conviction - does not fall within the ground of deportation. Criminal defense counsel, however, should assume that a conviction of aiding a deportable offense also constitutes a deportable offense and avoid such a conviction if possible.