United States v. Snellenberger, 480 F.3d 1187 (9th Cir. April 3, 2007) (a minute order, coupled with a charging document, is not sufficient under Shepard v. United States, 544 U.S. 13 (2005), to establish the nature of a prior conviction as a crime of violence for purposes of sentence enhancement for a conviction of illegal reentry after deportation); see United States v. Diaz-Argueta, 447 F.3d 1167, 1169 (9th Cir. 2006) (a minute order is "not a judicial record that can be relied upon" to establish the nature of a prior conviction).



Note that in Snellberger, the minute order said "P.C. 459 - 1st degree," which the court correctly states means residential burglary and this is what the information said. But, the court said that a minute order is not sufficient under Shepard because it is not a plea agreement, plea colloquy where the defendant assented, or a comparable judicial document. The BIA in an unpublished opinion had said it is a "comparable" judicial document.