Gattem v. Gonzalez, 412 F.3d 758 (7th
Cir. June 20, 2005) (Illinois conviction of misdemeanor solicitation
to engage in a sexual act, in violation of 720 ILCS § 5/11-14.1(a),
is an aggravated felony sexual abuse of a minor offense for
immigration purposes where the criminal complaint (and no
other document) shows that the victim was under the age of
18).