Ninth Circuit: US v. David Rhinehart

Where the terms of a sentencing enhancement predicate are defined in a proximate section of the law, the inquiry into the predicates is not one of subjective relation, but instead the usual categorical comparison to the federal generic crime.

State statutes are categorically broader than the federal offense; disjunctive list following a statement of the offense does not establish divisibility.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/06/18/16-10409.pdf