United States v. Christensen, 559 F.3d 1092 (9th Cir. Mar. 23, 2009) (Washington state conviction of statutory rape, in violation of Washington Revised Code 9A.44.079, did not constitute a "violent felony," so as to justify a sentence enhancement from 10 to 15 years for being a felon in possession of ammunition in violation of 18 U.S.C. 922(g)(1) and 924, under the categorical approach of Taylor v. United States, 495 U.S. 575 (1990), because that offense may involve consensual sexual intercourse).