Ninth Circuit -- USA V. JASON LEE

Guilty plea where the charging document articulates several theories of the crime, only some of which establish it as a predicate for a subsequent sentencing, is insufficient to establish the predicate under modified categorical review.

Where statute allows for reduced sentence where certain findings are made - findings that would remove the conviction as a predicate - and the reduced sentence is made without findings on the record, the reduced sentence in itself is insufficient to disqualify the conviction as a valid predicate.

No error in denial of entrapment instruction.

USA V. JASON LEE