United States v. Becerril-Lopez, 528 F.3d 1133 (9th Cir. Jun.12, 2008) (California conviction of robbery, in violation of Penal Code 211, constituted crime of violence, for purposes of 16-level enhancement of illegal reentry sentence under USSG 2L1.2(b), which contains no reference to 18 U.S.C. 16(b)), distinguishing United States v. McDougherty, 920 F.2d 569, 574 (9th Cir. 1990) (holding California robbery, under Penal Code 211, constituted a crime of violence under USSG 4B1.2 commentary language as well as 18 U.S.C. 16(b), covering any felony that involved a "substantial risk" that physical force may be used "against the person or property of another", a definition broader than the definition contained in 4B1.2 alone, which identified only those crimes presenting a substantial risk of physical injury to another person (not to property).).