United States v. Caceres-Olla, 738 F.3d 1051 (9th Cir. Dec. 23, 2013) (Florida conviction for "lewd and lascivious battery," in violation of Florida Statutes 800.04(4)(a), [[e]ngag[ing] in sexual activity with a person 12 years of age or older but less than 16 years of age.], did not categorically constitute a forcible sex offense, and thus cannot be a crime of violence as defined under the federal sentencing guidelines).

 

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