In Lorenzo v. Sessions (Aug. 29 2018), the Ninth Circuit ruled that the California definition of methamphetamine punishes offenses that are not punished on the federal schedule of controlled substances. Because the California statute is “overbroad,” the court determined that no California conviction for methamphetamines could fall within the controlled substances ground of removability. This advisory will provide guidance for immigration attorneys, criminal defenders, and post-conviction specialists seeking to implement Lorenzo v. Sessions.