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:
http://cdn.ca9.uscourts.gov/datastore/opinions/2018/01/29/16-73085.pdf