Patel v. Ashcroft, 401
F.3d 400 (6th Cir. Mar. 8, 2005) (Illinois conviction of criminal
sexual abuse, in violation of 720 Ill. Comp. Stat. § 5/12-15,
constituted a crime of violence under 18 U.S.C. § 16(b), and
was therefore an aggravated felony under INA § 101(a)(43)(F),
8 U.S.C. § 1101(a)(43)(F), "because of the disparate
ages of the defendant and the victim, or the mental incapacity
or physical helplessness of the victim, or the defendants
position of authority over the victim, the crime, semper et
ubique, includes a substantial risk of physical force.").