United States v.
Sandoval-Barajas, 206 F.3d 853 (9th Cir. Mar. 13, 2000), cert.
denied, 122 S.Ct. 408 (2001) (Washington conviction for possession
of firearm by noncitizen, in violation of R.C.W. § 9.41.170,
was not an aggravated felony, under INA § 101(a)(43)(E), 8
U.S.C. § 1101(a)(43)(E), for purposes of 16-level enhancement
under Sentencing Guidelines for illegal re-entry conviction,
since the state statute was broader than the applicable federal
statute).