The Ninth Circuit holds that a California rape conviction under Penal Code section 261(a)(2) is a categorical match for the federal generic definition of rape, qualifying as an aggravated felony and defeating an illegal-reentry defendant's collateral attack on his prior removal order.
Fourth District grants Penal Code section 1473.7 relief where defense counsel failed to recognize and pursue an immigration-safe plea after Sessions v. Dimaya and United States v. Lynch opened the door to one.