The Ninth Circuit has determined that an Alabama conviction for first-degree robbery is not a violent felony under the Armed Career Criminal Act because the statute only requires a minimal use of force. Given the similarity between the definition of a violent felony and a crime of violence in the immigration context, this decision could have persuasive value in immigration proceedings.
The full text of US v. Walton can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2018/02/01/15-50358.pdf