U.S. v. Strickland, No. 08-30091 (3-2-09). The 9th considers whether a prior Maryland conviction for "child abuse" qualifies as a predicate offense to increase a federal minimum/maximum in a child pornography case. It does. However, it does only under a modified categorical approach, because the state statute used to cover both physical and sexual assault under "child abuse." The modified categorical approach was met because, while the docket of the charging counts was uncertified, the defendant later signed sex registration forms in two states, and the forms related or made reference back to the Maryland conviction.