The Sixth Circuit has determined that an Ohio robbery statute does not necessarily require the intentional infliction of violence force, and therefore, does not match the definition of a crime of violence. Specifically, the court noted that the reckless use of force can still result in injury to a victim.

The full text of US v. Butts can be found here:

https://www.opn.ca6.uscourts.gov/opinions.pdf/22a0163p-06.pdf

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