The Ninth Circuit has determined that a Washington conviction for first-degree assault is a crime of violence. It distinguished its prior case law on the overbreadth of Washington’s accomplice liability, finding it inapplicable to the elements-based definition of a crime of violence.

The full text of Amaya v. Garland can be found here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2021/10/07/18-70060.pdf

Comment