Kwong v. Holder, ___ F.3d ___, 2011 WL 6061513 (9th Cir. Dec. 7, 2011) (abstract of judgment, as a document prepared by the court, is acceptable evidence to establish the crime a defendant was convicted of; suggesting that United States v. Navidad"Marcos, 367 F.3d 903 (9th Cir. 2004) (abstract of judgment insufficient to establish crime of conviction) was overruled by United States v. Snellenberger, 548 F.3d 699 (9th Cir.2008) (en banc)).

Note: This decision speaks to the use of the abstract of judgment to identify the crime of conviction, not the nature of the conviction.