The Eighth Circuit has determined that Wisconsin's burglary statute is divisible in light of the Supreme Court's decision in Mathis v. United States.  The court further determined that subsection a of the statute, which criminalized burglary of any building or dwelling, is a match to the generic definition of burglary.  Although this determination arose in the context of a federal sentencing case, given the similarity between the definition of a burglary offense under sentencing law and the definition of a burglary aggravated felony in the immigration context, this decision could be persuasive in the immigration context.

The full text of U.S. v. Lamb can be found here: