Almanza-Arenas v. Holder, ___ F.3d ___ (9th Cir. Nov. 10, 2014) (California conviction of violating Vehicle Code 10851(a), a statute that criminalizes both conduct that would constitute a crime of moral turpitude " taking a vehicle with intent permanently to deprive the owner, and conduct that does not amount to a crime of moral turpitude " intent temporarily to deprive the owner " is not a divisible statute, because it creates a minimum intent of at least temporarily depriving the owner of the property, rather than different offenses with different elements as to which the jury must unanimously agree; the immigration authorities may not apply the modified categorical analysis or consider the record of conviction, even in the context of inadmissibility and eligibility to apply for non-LPR cancellation of removal where the respondent bears the burden of proof).