Bautista v. Atty Gen. of the U.S., 744 F.3d 54, 59 (3d Cir. Feb. 28, 2014) (Section 101(a)(43) uses defined in when the reference to a federal statute is preceded by criminal conduct terms, such as illicit trafficking of drugs or crime of violence, which Congress has chosen to define by reference to a federal statute. In these defined in subsections of 101(a)(43), the state conviction need not be punishable under that federal statute but need only include the listed criminal conduct, as it is defined by the federal statute. In contrast, Congress employs described in to classify a state conviction as an aggravated felony when an offense would be punishable under a federal statute because the conduct or state statute of the conviction encompasses the same elements as a federal statute. These federal statutes are not definitional but, rather, describe a specific type of offense.).