United States v. Fernandez-Cusco, __ F.3d __ (5th Cir. Apr. 20, 2006) (examining for plain error, the court found that where the complaint charges defendant under a subsection of a divisible statute that is a categorical crime of violence, but the plea colloquy does not indicate any specific subsection, it is not plain error for the illegal re-entry sentencing court to find that the defendant had pleaded guilty to the subsection charged in the complaint).
http://caselaw.lp.findlaw.com/data2/circs/5th/0540289cr0p.pdf

jurisdiction: 
Fifth Circuit

 

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