In a follow up to several published and unpublished decisions that have suggested this holding, the Ninth Circuit issued a published decision finding that California theft crimes (which include theft of labor and theft by false pretenses) are overbroad and indivisible compared to the generic definition of a theft offense. As such, they will never qualify as theft aggravated felonies, regardless of the sentence imposed.
The full text of Lopez-Valencia v. Lynch can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2015/08/17/12-73210.pdf