Patel v. Mukasey, 526 F.3d 800, ___ (5th Cir. Apr. 29, 2008) (court of appeals enforces record of conviction limitation, of categorical analysis, and holds it improper to go beyond record of conviction where the statute defining the offense of conviction does not contain disjunctive elements or divisible subsections creating multiple offenses: "The purpose of the categorical approach is to avoid "the practical difficulties and fairness problems that would arise if courts were permitted to consider the facts behind prior convictions .... [which] would potentially require federal courts to relitigate a defendant's prior conviction in any case where the government alleged that the defendant's actual conduct fit the definition of a predicate offense."), citing Taylor v. United States, 495 U.S. 575, 601, 110 S.Ct. 2143, 109 L.Ed.2d 607 (1990)).