The following excerpt is from Silva v. Garland, 993 F.3d 705 (9th Cir. 2021):
5 Neither party argues that we should apply the modified categorical approach here, see, e.g. , Shepard v. United States , 544 U.S. 13, 26, 125 S.Ct. 1254, 161 L.Ed.2d 205 (2005), so we do not address that issue.
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