The Eighth Circuit has had that an Arkansas conviction for residential burglary does not qualify as a violent felony under the Armed Career Criminal Act (ACCA) because it encompasses the burglary of certain types of vehicles.  The court also found that the statute was indivisible with respect to what type of structure was being burglarized.  Given the similar definition of generic burglary for ACCA purposes and aggravated felony purposes, this decision could have persuasive value in the immigration context.

The full text of US v. Sims can be found here: