In Young v. Holder, 697 F.3d 976 (9th Cir. Sept. 17, 2012) (en banc), the Ninth Circuit held that Petitioner failed to exhaust the claim that his conviction was not for a violation of a law relating to a controlled substance within the meaning of 8 U.S.C. 1227(a)(2)(B)(i), so the court lacked jurisdiction over that claim. It also held that the evidentiary limitations articulated in Shepard v. United States, 544 U.S. 13, 26 (2005), apply when determining, under the modified categorical approach, whether a prior conviction renders an alien ineligible for cancellation of removal as an aggravated felon under 8 U.S.C. 1229b. It held that under the modified categorical approach, a guilty plea to a conjunctively phrased charging document establishes only the minimal facts necessary to sustain a defendant's conviction. In other words, when a conjunctively phrased charging document alleges several theories of the crime, a guilty plea establishes a conviction under at least one, but not necessarily all, of those theories. In so deciding, the court reconciled its inconsistent precedents on this issue by adopting one line of cases"including Malta"Espinoza v. Gonzales, 478 F.3d 1080, 1082 n.3 (9th Cir.2007)"and rejecting the other, including United States v. Snellenberger, 548 F.3d 699, 701(9th Cir.2008) (en banc) (per curiam). Finally, it held that an alien cannot carry the burden of demonstrating eligibility for cancellation of removal by merely establishing that the relevant record of conviction is inconclusive as to whether the conviction is for an aggravated felony. It overruled Sandoval"Lua v. Gonzales, 499 F.3d 1121, 1130"31(9th Cir.2007), and Rosas"Castaneda v. Holder, 655 F.3d 875, 883"84 (9th Cir.2011), to the extent that they conflict with this holding.