The Eighth Circuit has determined that a New York second-degree robbery conviction qualifies as a crime of violence under the federal sentencing guidelines. The court noted that the statute requires the defendant to “forcibly steal” property from the victim, and that the force must be capable of causing physical pain or injury.

The full text of US v. Williams can be found here:
http://media.ca8.uscourts.gov/opndir/18/08/171632P.pdf

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