The Ninth Circuit has determined that a conviction under section 10851 of the CA Vehicle Code (taking a vehicle without consent, commonly referred to as “joyriding”) is overbroad and indivisible when compared to the generic definition of a theft offense. The court overruled its prior finding that the statute is divisible in Duenas-Alvarez.
The full text of Lopez-Marroquin v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2021/08/18/18-72922.pdf