United States v. Sandoval-Barajas,
206 F.3d 853 (9th Cir. Mar. 13, 2000), cert. denied, 122 S.Ct.
408 (2001) (Washington conviction for possession of firearm
by noncitizen, in violation of R.C.W. § 9.41.170, was not
an aggravated felony, under INA § 101(a)(43)(E), 8 U.S.C.
§ 1101(a)(43)(E), for purposes of 16-level enhancement under
Sentencing Guidelines for illegal re-entry conviction, since
the state statute was broader than the applicable federal
statute).