Parrila v. Gonzales
No. 03-74010 (7-11-05). This is an immigration case in which the 9th agreed that Washington Revised Code sec. 9.68A.090 did not categorically proscribe "sexual abuse of a minor" because the abuse could be via communications. However, the factual basis under the Shepard test (looking at the plea) makes it an agg felony.
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