Kwong v. Holder

Issue: (1) Whether an abstract of judgment, which is prepared by a court clerk for sentencing purposes after a defendant"s guilty plea and without the defendant"s input, quali?es as a conclusive record made or used in adjudicating guilt suf?cient to determine the nature of a prior conviction under Shepard v. United States; and (2) whether a burglary conviction in a state that does not require an unlawful or unprivileged entry can be considered a crime of violence under Leocal v. Ashcroft, when it is not a violent felony under Taylor v. United States.