United States v. Contreras-Salas, 387 F.3d 1095 (9th Cir. Nov. 3, 2004) (Judgment of conviction and charging documents alone insufficient in jury trial to show noncitizen was convicted of aggravated felony portion of a divisible Nevada child abuse statute; jury instructions and/or verdict required to show elements of which noncitizen was found guilty).
http://caselaw.lp.findlaw.com/data2/circs/9th/0310710p.pdf