Jeune v. Attorney General, 476 F.3d 199, 2007 WL 512510 (3d Cir. Feb. 20, 2007) ("Moreover, this Court has indicated that we must assume that Jeune's conduct was only the minimum necessary to comport with the statute and record. Partyka v. Att'y Gen. of U.S., 417 F.3d 408, 411 (3d Cir.2005) ("Under this categorical approach, we read the applicable statute to ascertain the least culpable conduct necessary to sustain a conviction under the statute."); Wilson v. Ashcroft, 350 F.3d 377, 381 (3d Cir.2003) ("Because the state statute under which Wilson pled guilty does not contain sale for remuneration as an element, we cannot determine from the state court judgment that Wilson's conviction necessarily entails a finding of remuneration."); Steele v. Blackman, 236 F.3d 130, 136 (3d Cir.2001) (limiting the inquiry to what the state court must necessarily have found). To conform with these precedents, we must conclude that Jeune's conduct was the bare minimum necessary to trigger 35 PA. CONS.STAT. ANN. 780-113(a)(30) and therefore does not constitute an aggravated felony.").