Penuliar v. Ashcroft,
395 F.3d 1037 (9th Cir. Jan. 12, 2005) (California conviction
of unlawful driving or taking a vehicle, in violation of Vehicle
Code § 10851(a), was not a theft offense, within the meaning
of INA § 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G), because
the statute and charge both were overbroad with respect to
the definition of a theft offense by encompassing not only
substantive theft offenses but aiding and abetting them as
well).