In the context of a federal sentencing case, the Eighth Circuit has determined a Michigan conviction for robbery is a violent felony.  The statute, which requires the defendant “assault or put[] in fear” the victim, is limited to conduct that accomplishes a forceful taking (or attempted taking) by using violence or the threat of violence to put the victim in fear of immediate personal injury.  Given the similarity between the definition of a violent felony and a crime of violence in the immigration context, this decision likely applies to a crime of violence aggravated felony analysis in the immigration context as well.


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