United States v. Chavarriya-Mejia, 2004 WL 908886 (11th Cir. April 29, 2004) (Kentucky rape in the third degree, "statutory rape" in violation of Ky.Rev.Stat. 510.060 is a "crime of violence" under U.S.S.G. 2L1.2, as the Kentucky statute assumes lack of consent, and "sexual offenses by adults against children inherently involve physical force against children.").
http://caselaw.findlaw.com/data2/circs/11th/0310753p.pdf