The Ninth Circuit has determined that the federal bank robbery statute, which requires the use force, violence, and intimidation, is a crime of violence under federal sentencing guidelines. With respect to the possible use of intimidation, the Court noted that intimidation requires that the defendant take property in such a way that would put an ordinary, reasonable person in fear of bodily harm and that a defendant cannot put a reasonable person in fear of bodily harm without threatening to use force capable of causing physical pain or injury.
Given the similarity between the definition of a crime of violence under the sentencing guidelines and in the immigration context, this case could have persuasive impact in immigration proceedings.
The full text of US v. Watson can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2018/02/01/16-15357.pdf