U.S. v. Zuniga-Galeana

Dist. Ct. did not commit plain error in sentencing defendant to 41-month term of incarceration on charge of illegal reentry into U.S. after having been deported, even though defendant argued that Dist. Ct. improperly increased his offense level by 16 levels for having been previously convicted of “crime of violence” arising out of 1991 Illinois conviction for aggravated criminal sexual abuse of his 15-year-old girlfriend. Defendant’s argument was rejected in Martinez-Carrillo, 250 F.3d 1101, where Ct. indicated that conviction for sexual abuse of minor qualified for instant 16-level increase because victim of said crime was younger than 18, and where defendant's Illinois conviction defined age of consent more narrowly.