The Eleventh Circuit has determined that a New York conviction for sexual misconduct is not categorically a rape aggravated felony. The court declined to determine if the conviction - which covers both statutory and forcible rape offenses - is divisible. Assuming divisibility, the court found that the complaint did not establish whether the petitioner was convicted of a forcible or statutory rape offense. The complaint alleged that he engaged in both types of rape, and the plea itself did not specify to which form of rape he pled.
The full text of George v. Attorney General can be found here:
http://media.ca11.uscourts.gov/opinions/pub/files/201814000.pdf