United States v. Rosales-Garcia, 667 F.3d 1348 (10th Cir. Feb. 7, 2012) (the 16"level enhancement in USSG 2L1.2(b)(1)(A) does not apply to a defendant whose later probation-violation sentence for an earlier drug trafficking felony was made longer than 13 months after the defendant was deported and committed the base offense of illegal reentry); see United States v. Lopez, 634 F.3d 948 (7th Cir.2011); United States v. Bustillos-Pena, 612 F.3d 863, 869 (5th Cir.2010) (relying on the rule of lenity and concluding that it is error to implement the sixteen-level enhancement in analogous factual circumstances); United States v. Lopez, 634 F.3d 948, 950 (7th Cir.2011) (We hold that [the defendant's] later sentence on probation revocation after his deportation and reentry should not count under section 2L1.2(b)(1)(A)(i).), and United States v. Guzman-Bera, 216 F.3d 1019, 1021 (11th Cir.2000) (applying an earlier version of 2L1.2(b)(1)(A) when determining whether the defendant had committed an aggravated felony and concluding that a post-deportation and - illegal reentry sentence lengthening should not have been used for enhancement purposes under U.S.S.G. 2L1.2(b)(1)(A)); but see United States v. Compres-Paulino, 393 F.3d 116, 118 (2d Cir.2004) (per curiam) (holding that the defendant illegally reentered the United States after having been convicted of a drug trafficking offense for which the sentence imposed exceeded 13 months in analogous factual circumstances) (internal quotations omitted); see also United States v. Jimenez, 258 F.3d 1120, 1126"27 (9th Cir.2001) (stating in dictum that the presence vel non of an aggravated felony for purposes of 2L1.2 turns on whether the statutory elements of such a felony were met prior to ... deportation and reentry).