The Ninth Circuit has determined that a North Carolina conviction for breaking and entering can qualify as a predicate burglary offense under the Armed Career Criminal Act (ACCA). In so doing, the court determined that generic burglary includes burglary of mobile structures customarily used or adapted for overnight accommodation, such as mobile homes. Given the similar definition of a burglary predicate offense under the ACCA and a burglary aggravated felony in the immigration context, this decision could have persuasive impact in immigration cases.
The full text of Mutee v. United States can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2019/04/04/17-15415.pdf