United States v. Ladwig,
432 F.3d 1001 (9th Cir. Dec. 27, 2005) (Washington felony
conviction for making harassing telephone call under R.C.W.
§ 9.61.230(3)(b), is a "violent felony" predicate
offense under the Armed Career Criminal Act, 18 U.S.C. § 924(e),
because it has a threat of use of physical force against the
person of another, and is a felony only if committed by a
threat to kill, which is a conduct-based sentence enhancement
that can be considered part of the record of conviction in
making this determination).