The Ninth Circuit has determined that a Nevada conviction for attempted lewdness with a child under the age of 14 is an attempted sexual abuse of a minor aggravated felony. In so doing, the court confirmed that its Medina-Villa definition of sexual abuse (involving abusive contact with a minor) is not irreconcilable with the Supreme Court’s decision in Esquivel-Quintana (addressing when statutory rape crimes qualify as sexual abuse of a minor aggravated felonies).

The full text of Leon Perez v. Garland can be found here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2024/06/28/23-204.pdf

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