Patel v. Ashcroft, 401 F.3d 400
(6th Cir. Mar. 8, 2005) (Illinois conviction of criminal sexual
abuse, in violation of 720 Ill. Comp. Stat. § 5/12-15, constituted
a crime of violence under 18 U.S.C. § 16(b), and was therefore
an aggravated felony under INA § 101(a)(43)(F), 8 U.S.C.
1101(a)(43)(F), "because of the disparate ages of the
defendant and the victim, or the mental incapacity or physical
helplessness of the victim, or the defendants position of
authority over the victim, the crime, semper et ubique, includes
a substantial risk of physical force.").