United States v. Alejandro Zuniga-Galeana

Defendant-Appellant, Alejandro Zuniga-Galeana (“Zuniga”), pleaded guilty to illegal reentry after deportation, see -8' U.S.C. § 1326(a), and was sentenced to 41 months’ imprisonment. He appeals, arguing that the district court improperly increased his total offense level by 16 for previously having been convicted of a “crime of violence,” see U.S.S.G. § 2L1.2(b)(l)(A) (2014) — specifically, a 1991' conviction in Illinois for aggravated criminal sexual abuse. He contends that the categorical approach requires a narrower understanding of the generic definitions of “sexual abuse of a minor” and…