United States v. Rios-Beltran, 361 F.3d 1204 (9th Cir. March 24, 2004) (the statutory maximum, not the sentence range under applicable State sentencing guidelines, determines whether given offense qualifies as felony for federal sentencing purposes; prior Oregon conviction punishable by a maximum term of imprisonment of more than one year is an "aggravated felony" for federal sentencing purposes).