Coronado v. Holder, ___ F.3d ___, 2014 WL 3537027 (9th Cir. Jul. 18, 2014) (Superseding amended opinion) (California offense of possession of a controlled substance, in violation of Health & Safety Code 11377(a), is a divisible statute, since some substances are federally listed and trigger deportation and removal, and others are not, so inadmissibility under INA 212(a)(2)(A)(i)(II), 8 U.S.C. 1182(a)(2)(A)(i)(II) must be assessed under the modified categorical analysis); Descamps v. United States, ___ U.S. ___, 133 S.Ct. 2276, 2281, 186 L.Ed.2d 438 (2013) (stating that the modified categorical approach applies only to prior convictions under a divisible statute, one that sets out one or more elements of the offense in the alternative).

 

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