Carlos Quinteros-Cisneros v. Jefferson B. Sessions III

As state law distinguishes sentencing enhancements from aggravating circumstances and requires sentencing enhancements to be included in the charge, an element of a sentencing enhancement can make the conviction a predicate felony in an immigration removal proceeding.

As sexual abuse of a minor is per se abusive, the conviction is a valid predicate as a crime of abuse.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/06/11/13-72632.pdf