The following excerpt is from United States v. Townsend, 897 F.3d 66 (2nd Cir. 2018):
modified categorical approach. Mathis v. United States , U.S. , 136 S.Ct. 2243, 2248-49, 195 L.Ed.2d 604 (2016). Which approach a court takes turns on whether the state statute defining the crime of conviction is divisible or indivisible. Id. at 2249.
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