United States v. Gutierrez-Ramirez, __ F.3d __, 2005 WL 762664 (5th Cir. April 2, 2005) (Although strict limitation to examination of statutory elements of statute of conviction is not required to determine whether an offense is a "drug trafficking offense" for sentence enhancement purposes, the courts are limited to examination of the indictment and/or jury instructions; California abstract of judgment could not be used to determine that noncitizens prior drug conviction was a "drug trafficking offense").