United States v. Becerril-Lopez, 528 F.3d 1133 (9th Cir. Jun. 12, 2008) (to show conviction does not fall within ground of removal, noncitizen must show reasonable probability that the state would apply its statute to conduct outside the generic definition, which in the Ninth Circuit can be done by showing that the text of the state statute expressly includes a broader range of conduct than the Guideline: "In Duenas-Alvarez, the defendant's argument relied not on the express text of the statute at issue, but on how state courts might conceivably apply it. The Supreme Court held that to prevail, the defendant had to show either that the statute was applied this way in his own case, or "point to ... other cases in which the state courts in fact did apply the statute in the special (nongeneric) manner for which he argues." Duenas-Alvarez, 127 S.Ct. at 822), citing United States v. Vidal, 504 F.3d 1072, 1082 (9th Cir. 2007) (en banc); United States v. Grisel, 488 F.3d 844, 850 (9th Cir. 2007) (en banc)).