Nguyen v. Holder, 571 F.3d 524 (6th Cir. Jul. 2, 2009) (California conviction of auto theft, in violation of what is now codified at Penal Code 487(d)(i) and 18 U.S.C. 16(b), both criminal statutes, are ambiguous: "[A]ny doubt about [deportability] must be resolved in favor of the . . . petitioner who is subject to deportation pursuant to an ambiguous criminal statute. . . . Because we cannot find that auto theft is "unambiguously" a crime of violence under Section 16(b), we should follow the ancient rule and overrule the administrative agency in this case."; citing United States v. Santos, __U.S.__, 128 S.Ct. 2020, 2025 (2008) (plurality); United States v. Bass, 404 U.S. 336, 347-49 (1971); United States v. Ford, 560 F.3d 420, 425 (6th Cir. 2009) (applying the "rule of lenity" to a previous conviction for a "walkaway" escape because it is not unambiguously a "crime of violence" and therefore cannot serve as the basis for career offender status).