Gabriel Almanza-Arenas v. Loretta E. Lynch

I agree that Gabriel Almanza-Arenas’ conviction under California Vehicle Code § 10851(a) is not a conviction for a crime involving moral turpitude. But I disagree with the court’s conclusion, predicated on the same reasoning our court adopted in Rendon v. Holder, 764 F.3d 1077 (9th Cir.2014), that § 10851(a) is an “indivisible” statute. I would overrule Rendon, as I think its approach to divisibility analysis is inconsistent with the approach required by Descamps v. United States, — U.S. -, 133 S.Ct. 2276, 186 L.Ed.2d 438 (2013). I will be the first to admit, though, that the correct reading…