In this case, the Ninth Circuit addressed "whether a defendant convicted of second-degree robbery under section 9A.56.190 of the Revised Code of Washington and sentenced to prison
for at least one year has been convicted of an aggravated felony." The court reiterated its long-standing definition of a theft offense as a crime that requires (1) the taking of (2) property (3) without consent (4) with the intent to deprive the owner of rights and benefits of ownership.
The State of Washington defines second-degree robbery as the taking of personal property from the person of another or in his or her presence against his or her will, when accompanied by the use of force or the fear of injury. The court noted that though the statute does not
explicitly provide that specific intent to steal is an element of the crime, the state courts have so held. Thus, it summarized the elements of Washington second-degree robbery as (1) taking (2) personal property (3) from another person or from another’s immediate presence (4) against his or her will (5) by force or threatened force (6) with the specific intent to steal. This definition, the court concluded, covered the full range of conduct included in the generic definition of a theft offense. Therefore, the crime was a categorical match for the generic definition, and because the defendant had been sentenced to the required one year term of imprisonment listed in the theft aggravated felony definition, he had been convicted of an aggravated felony.
The full text of United States v. Alvarado-Pineda can be read here: http://cdn.ca9.uscourts.gov/datastore/opinions/2014/12/19/13-50528.pdf