Huerta-Guevara
v. Ashcroft, 321 F.3d 883 (9th Cir. Mar. 4, 2003) (Arizona
conviction of possession of a stolen vehicle, in violation
of A.R.S. § 13-1802, did not fall within the generic definition
of "theft offense" necessary to constitute an aggravated
felony under INA § 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G),
since the Arizona statute was overbroad, with respect to the
generic definition, because (a) it prohibited "theft
of services," which are not considered property and therefore
fall outside the generic definition of theft, (b) it prohibited
aiding and abetting, and (c) it "is a divisible statute,
four subparts of which do not require intent.").