Young v. Holder, 697 F.3d 976 (9th Cir. Sept. 17, 2012) (en banc) (Under the modified categorical approach, a guilty plea to a conjunctive count does not necessarily admit every possible version of the crime. . . . [U]nder the modified categorical approach, when a conjunctively phrased charging document alleges several theories of the crime, a guilty plea establishes conviction under at least one of those theories, but not necessarily all of them. . . . In sum, when either A or B could support a conviction, a defendant who pleads guilty to a charging document alleging A and B admits only A or B. Thus, when the record of conviction consists only of a charging document that includes several theories of the crime, at least one of which would not qualify as a predicate conviction, then the record is inconclusive under the modified categorical approach.).