The Board of Immigration Appeals (BIA) has determined that extortionate takings qualify as theft offenses because takings accomplished through threats, fear, or force are essentially non-consensual. Accordingly, the BIA held that a California robbery conviction is a theft offense aggravated felony.
The full text of Matter of Ibarra can be found here:
https://www.justice.gov/sites/default/files/pages/attachments/2016/09/15/3872.pdf