In an unpublished disposition, the Ninth Circuit found an insufficient connection between the minute order and a complaint.  The minute order stated that the defendant pled guilty to count one in the complaint.  However, it also stated "DA to file amended info."  The Court found that the Government had failed to prove by clear and convincing evidence that the defendant had pled guilty to count one as enumerated in the complaint, and thus, under the modified categorical approach, the complaint was not sufficient to establish the identity of the substance involved in the offense.

The full text of Sanchez-Nino v. Lynch can be found here: