United States v. Castillo-Rivera,
244 F.3d 1020 (9th Cir. Mar. 26, 2001), cert. denied, 122
S.Ct. 294 (2001) (California conviction for violating California
Penal Code § 12021(a), felon in possession of a firearm, constitutes
an aggravated felony under INA § 101(a)(43)(E), 8 U.S.C.
1101(a)(43)(E), because it is "an offense described in"
18 U.S.C. § 922(g)(1), the federal felon-in-possession statute,
even though the state crime, unlike § 922(g), does not include
any interstate or foreign commerce federal jurisdictional
element, and therefore supports sentence enhancement under
U.S.S.G. § 2L1.2(b)(1)(A) for illegal re-entry conviction
of violating INA § 176(a), 8 U.S.C. 1326(a)).