The Ninth Circuit has determined that a California conviction for carjacking does not include the requisite intent to steal to be considered a theft aggravated felony. “[A]n individual can be convicted of violating California’s carjacking statute even if they take a car from someone who has an inferior possessory interest in the car—or none at all.” The court also concluded that the statute is not divisible.
The full text of US v. Orozco-Orozco can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/03/12/22-50146.pdf