The Ninth Circuit has determined that a California forgery statute is a categorical match to the definition of a forgery aggravated felony. “Thus, by definition, § 470a requires proof of a false writing capable of procuring fraud. A person who takes the affirmative step to photocopy a genuine document with the intent to deceive has made a false instrument—an action that falls squarely within the generic definition of forgery.”
The full text of Escobar Santos v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/07/09/17-72334.pdf