United States v. Gonzalez-Castillo, 562 F.3d 80 (1st Cir. Apr. 9, 2009) (illegal reentry sentence reversed, where district court based the sentence on a "fact" - the assertion that this was the defendant's second illegal entry into the United States - that was not supported by the record, since that constitutes procedural error); Gall v. United States, __ U.S. __, ___, 128 S.Ct. 586, 597, 169 L.Ed.2d 445 (2007) (procedural errors include "selecting a sentence based on clearly erroneous facts."); United States v. Torres, 541 F.3d 48, 51 (1st Cir.2008) (listing "selecting a sentence based on clearly erroneous facts" as among the "procedural errors amounting to an abuse of discretion" by the sentencing court).