United States v. Hernandez-Hernandez,
374 F.3d 808 (9th Cir. June 30, 2004) (California felony conviction
of false imprisonment, in violation of Penal Code § 236,
237, is a divisible statute, as it may be committed by violence,
menace, fraud or deceit; the record of conviction, which included
by stipulation the statement of facts contained in a motion
filed in the criminal case, established that the conviction
occurred under the violence portion of the statute; conviction
therefore constituted a crime of violence aggravated felony
conviction, supporting a 16-level enhancement of sentence
for illegal re-entry under U.S.S.G. § 2L1.2(b)(1)(A)(ii)).