The Ninth Circuit has determined that a petitioner who was convicted in California of second degree murder under an aiding and abetting theory has been convicted of an aggravated felony.  The court relied on the Supreme Court's 2007 decision in Gonzalez v. Duenas-Alvarez, finding that there have been no material changes to California's aiding and abetting case law.

The full text of Sales v. Sessions can be found here: