United States v. Becerril-Lopez, 528 F.3d 1133 (9th Cir. Jun.12, 2008) (Guidelines definitions of crime of violence differ from immigration definition and from each other); United States v. Beltran-Mungia, 489 F.3d 1042, 1049 (9th Cir. 2007) (a state crime that satisfies the "crime of violence" definition in USSG 4B1.2 does not automatically satisfy the definition in 2L1.2, since 4B1.2 has "materially different" wording from 2L1.2; while 4B1.2 contains a catch-all for crimes presenting a "serious potential risk of physical injury," 2L1.2 covers only those crimes that involve "the use, attempted use, or threatened use of physical force against the person of another.").