United States v. Gomez-Gomez, 547 F.3d 242. (5th Cir. Oct. 21, 2008) (en banc) (California conviction of rape, under Penal Code 261(a)(2) (1991) [sexual intercourse "accomplished against a person's will by means of force, violence, duress, menace, or fear of immediate and unlawful bodily injury on the person of another."], where duress encompassed "a direct or implied threat of ... hardship, or retribution sufficient to coerce a reasonable person of ordinary susceptibilities." Cal. Penal Code 261(b), committed using nonphysical force, qualifies as a "forcible sex offense" and thereby a "crime of violence" under U.S.S.G. 2L1.2(b)(1)(A), sufficient to support 16-level sentence enhancement for illegal reentry after deportation).