The Ninth Circuit has determined that a federal conviction for voluntary manslaughter is a crime of violence. In a footnote, the court noted that its caselaw determining that California’s voluntary manslaughter statute is not a crime of violence is no longer tenable in light of intervening caselaw.

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

https://cdn.ca9.uscourts.gov/datastore/opinions/2023/10/17/17-15104.pdf

Comment