United States v.
Castillo-Rivera, 244 F.3d 1020 (9th Cir. Mar. 26, 2001), cert.
denied, 122 S.Ct. 294 (2001) (California conviction for violating
California Penal Code § 12021(a), felon in possession of a
firearm, constitutes an aggravated felony under INA § 101(a)(43)(E),
8 U.S.C. § 1101(a)(43)(E), because it is "an offense
described in" 18 U.S.C. § 922(g)(1), the federal felon-in-possession
statute, even though the state crime, unlike § 922(g), does
not include any interstate or foreign commerce federal jurisdictional
element, and therefore supports sentence enhancement under
U.S.S.G. § 2L1.2(b)(1)(A) for illegal re-entry conviction
of violating INA § 176(a), 8 U.S.C. 1326(a)).