The Ninth Circuit has determined that a federal conviction for armed robbery involving controlled substances is a crime of violence under federal sentencing law. The court rejected the petitioner’s argument that armed robbery by intimidation does not require the actual or threatened use of violent force. Given the similar definition of a crime of violence in the immigration and federal sentencing contexts, this decision could have persuasive effect in immigration litigation.
The full text of United States v. Burke can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2019/12/02/17-35446.pdf