In Martinez v. Att’y Gen., the 3rd Circuit employed the categorical approach in holding that the New Jersey state offense of criminal sexual contact, N.J.S.A. § 2C:14-3(b), constitutes sexual abuse of a minor, as defined in 8 U.S.C. § 1101(a)(43)(A). As a result, the New Jersey offense is an aggravated felony under the Immigration and Nationality Act.