United States v. Simo-Lopez, ___ F.3d ___, 2006 WL 3759302 (1st Cir. Dec. 22, 2006) (Puerto Rico conviction for aggravated battery, in violation of P.R. Laws Ann. tit. 33, 4032(e), was considered a misdemeanor under Puerto Rico law because the court imposed a sentence of six months confinement, which could only have lawfully been imposed on account of a misdemeanor conviction, and the conviction therefore did not qualify as a "crime of violence," under USSG 2L1.2 which requires a conviction to be a felony under the law of the jurisdiction of conviction before it can be considered a felony for federal illegal reentry sentence purposes of imposing a 16-level increase in the offense level).
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