United States v. Mejia-Barba, 327 F.3d 678, 2003 WL 21000811 (8th Cir. May 5, 2003)(Iowa conviction of identity theft, in violation of Iowa Code § 715A.8, constitutes aggravated felony as a "theft offense" as defined in INA § 101(a)(43)(G), 8 U.S.C. § 1101(a)(43)(G), for purposes of eight-level sentence enhancement under United States Sentencing Guideline § 2L1.2(b)(1)(C), for illegal reentry conviction).      This decision is very poorly reasoned, and should not be followed. It contradicts authority holding that the state label of an offense (e.g., as identity "theft") is not determinative of whether the conviction falls within an aggravated felony category. For example, auto "burglary" does not constitute "burglary" for aggravated felony purposes. See § 6.33, supra. Theft of services has held not to constitute "theft" for aggravated felony purposes, since aggravated felony "theft" includes only theft of property. United States v. Corona-Sanchez, 291 F.3d 1201 (9th Cir. June 6, 2002)(en banc) (California felony conviction of petty theft with a prior conviction, under California Penal Code §§ 484(a), 666, is a divisible statute with respect to the aggravated felony generic definition of theft offense, under INA § 101(a)(43)(G), 8 U.S.C. § 1101(a)(43)(G), as adopted by the Seventh and Tenth Circuits, since it includes conduct such as theft of labor and solicitation of a false credit report that is not included within the federal definition).