In a precedent decision issued today, the Fourth Circuit determined that a conviction in Virginia for unauthorized use of a vehicle does not qualify as a theft offense aggravated felony. After analysis state case law interpreting the statute of conviction, the court determined that it criminalizes de minimis deprivations of ownership interests, which the court described as "glorified borrowing." Because this conduct falls outside the generic definition of a theft offense, the conviction does not serve as a ground of removability. The language of the decision suggests (though does not explicitly state) that the statute is overbroad AND non-divisible, meaning that a modified categorical analysis will never be appropriate.
The full text of Castillo v. Holder can be found here: http://cdn.ca9.uscourts.gov/datastore/opinions/2015/01/14/13-10322.pdf