FORTUNATO P. BENAVIDES, Circuit Judge:
Rey David Guerrero-Navarro challenges the district court's classification of his 2009 conviction of Residential Burglary, WASH. REV. CODE Ann. § 9A.52.025, as a crime of violence for the purposes of United States Sentencing Guidelines Manual ("USSG") § 2L1.2(b)(1)(A). We affirm.
Guerrero-Navarro recently pled guilty to (1) knowing unlawful presence in the United States, in violation of 6 U.S.C. §§ 202(3) & 202(4); and (2) knowing possession of a firearm, in violation of 18 U.S.C. §§ 922(g)(5)(A) & 924(a)(2). The district court concluded that the aforementioned Washington state offense qualifies as a crime of violence under USSG § 4B1.2(a). After overruling Guerrero-Navarro's objection to this classification, the court enhanced his sentence accordingly. Guerrero-Navarro appeals, arguing that the offense cannot constitute the enumerated generic offense of burglary of a dwelling, because the statute defines "dwelling" more liberally than permitted by Taylor v. United States, 495 U.S. 575, 110 S.Ct. 2143, 109 L.Ed.2d 607 (1990). He does not contest any other aspect of the sentence calculation. Because Guerrero-Navarro raised timely objection, we review de novo. United States v. Murillo-Lopez, 444 F.3d 337, 339 (5th Cir.2006).
The Sentencing Guidelines allow enhancement when a previously deported alien unlawfully returns to the United States and has a prior conviction of a felony crime of violence. § 2L1.2(b)(1)(A). Crime of violence is defined, inter alia, as
"The generic offense of burglary contains at least the following elements: an unlawful or unprivileged entry into, or remaining in, a building or other structure, with intent to commit a crime." Taylor, 495 U.S. at 598, 110 S.Ct. 2143. Burglary of a dwelling, then, is the unlawful entry into or remaining within, with the intent to commit a crime, a "structure, tent, or vessel where someone lives." United States v. Castillo-Morales, 507 F.3d 873, 875 (5th Cir.2007). A review of the statutory language and judicial interpretation indicates that Washington's Residential Burglary offense is consistent with these standards and is not overbroad.
The state of Washington defines Residential Burglary as "enter[ing] or remain[ing] unlawfully in a dwelling other than a vehicle" with an "intent to commit a crime against a person or property therein." WASH. REV.CODE ANN. § 9A.52.025(1). A dwelling is "any building or structure ... which is used or ordinarily used by a person for lodging." Id. § 9A.04.110(7). "Building, in addition to its ordinary meaning, includes any dwelling, fenced area, vehicle, railway car, cargo container, or any other structure used for lodging of persons or for carrying on business therein...." Id. § 9A.04.110(5). Guerrero-Navarro contends that these statutory definitions result in an impermissibly broad rendering of the "dwelling" element of the generic offense. The other elements are not in dispute.
Guerrero-Navarro argues that Washington's statutory definitions suggest that dwelling may refer to fenced areas, cargo containers, or other structures impermissible under Taylor, 495 U.S. at 599, 110 S.Ct. 2143. We note, however, that the generic crime at issue here is not the one discussed in Taylor.
Even assuming that the Taylor discussion of buildings has some relevance here, it seems that the proffered non-generic interpretation is not consistent with the natural, common-sense reading of the statute in context. As a preliminary matter, we recognize that the definitions of building and dwelling established by the Washington legislature are not listed for the purpose of a single offense or a single statutory chapter, but for the purposes of the state's entire criminal code. WASH. REV.CODE ANN. § 9A.04.090. Consequently, the definitions must be broad enough to allow for appropriate interpretation in context. It makes sense, then, that the general definition of building would include storage containers and fences. Consider prohibitions on arson or vandalism: clearly legislators must protect many kinds of structures from these crimes. But this broad, general-purpose definition need not imply that a fence is a dwelling for the purpose of residential burglary. In fact, the modifying clause "ordinarily used for lodging" suggests that a dwelling will rarely — if ever — consist of a fenced area (or other unusual structure) alone.
Before deliberating a Residential Burglary case, Washington jurors are simply
We realize that a sister circuit examined the same offense and arrived at the opposite conclusion. See generally United States v. Wenner, 351 F.3d 969 (9th Cir. 2003). Ten years ago, that court concluded that Washington's statutory definitions combine to create an overly inclusive depiction of dwelling. Id. at 972. We disagree, and have the benefit of an additional decade of jurisprudence in which Washington's courts have consistently interpreted the term such that it denotes and connotes traditional structures, and only those used for human habitation. As already explained, this interpretation renders the definition consistent with the relevant legal standards. We conclude, therefore, that Washington's Residential Burglary offense, WASH. REV.CODE ANN. § 9A.52.025, constitutes the enumerated generic crime of burglary of a dwelling, and thus that the district court correctly classified Guerrero-Navarro's prior conviction as a crime of violence for the purposes of USSG § 2L1.2(b)(1)(A). Accordingly, we AFFIRM the interpretation and associated sentence enhancement.