The Ninth Circuit has determined that the California murder statute is overbroad when compared to the generic definition of murder because it includes murder of a fetus. However, the court determined that the statute is divisible between murder of a fetus and murder of a person, and therefore concluded under the modified categorical approach that the petitioner was convicted of an aggravated felony.
The full text of Gomez-Fernandez v. Barr can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/08/13/19-70079.pdf