The Ninth Circuit has determined that a California carjacking conviction is not a crime of violence because it does not require the use of violent force.  The Court overruled its prior decision in Nieves-Medrano v. Holder that had held a carjacking conviction is a crime of violence.  The case was remanded to allow the Board of Immigration Appeals to decide in the first instance if the conviction qualified as a theft offense aggravated felony.

The full text of Solorio-Ruiz v. Sessions can be found here: