United
States v. Rivera-Sanchez, 247 F.3d 905 (9th Cir. Apr. 18,
2001) (California conviction of sale, transportation, or solicitation
of sale, under California Health & Safety Code § 11360(a),
is under a divisible statute for purposes of deciding whether
the conviction is an aggravated felony for purposes of enhancing
a sentence for illegal re-entry, since the statute penalizes
offer to sell which is equivalent to solicitation, which has
been held not to constitute an aggravated felony or controlled
substances offense).