The Ninth Circuit has overruled its decision in Solorio-Ruiz v. Sessions, which held that a California conviction for carjacking is not a crime of violence, in light of the Supreme Court’s decision in Stokeling v. United States. The Supreme Court’s “clarification of ‘violent force’ (any force sufficient to overcome a victim’s physical resistance) is ‘clearly irreconcilable with our reasoning in Solorio-Ruiz. Our opinion rested on the analytical distinction between substantial and minimal force. This distinction no longer exists.”
The full text of U.S. v. Baldon can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2020/04/21/18-10411.pdf