See Immigrant Legal Resource Center, Practice Advisory, Great Ninth Circuit Case on Divisible Statutes: California Burglary Never Is Attempted Theft. In Rendon v. Holder the Ninth Circuit clarified when a statute is truly divisible under the categorical approach, and held that California burglary (Penal Code 459) never constitutes the aggravated felony attempted theft. This holding also means that California burglary never is a crime involving moral turpitude, under the categorical approach.
http://www.ilrc.org/resources/great-ninth-circuit-case-on-divisible-stat...