United States v. Gutierrez-Ramirez, 405 F.3d 352 (5th Cir. 2005) (California conviction of sale or transportation under Penal Code 11352(a) did not qualify as a drug trafficking conviction for purposes of enhancing a sentence for illegal reentry, where the sole basis for determining whether the conviction fell under the drug trafficking portion of this divisible statute was the abstract of judgment, which is not a source upon which the court can "rely to conclude that this short phrase manifests a 'conscious judicial narrowing of the charging document' rather than a shorthand abbreviation of the statute of conviction. We therefore agree with the Ninth Circuit that courts cannot exclusively rely on such shorthand descriptions to justify sentence enhancements under the Guidelines."), following United States v. Navidad-Marcos, 367 F.3d 903 (9th Cir. 2004).