The Ninth Circuit has determined that the an Arizona conviction for armed robbery does not qualify as a crime of violence under the force clause of the sentencing guidelines because the statute does not necessarily involve violent force. Given the similarity between the definition of a crime of violence in the immigration context and in the force clause, this decision could have persuasive value in the immigration context.
The full text of US v. Molinar can be found here:
An amended opinion was subsequently published here:
In a follow up decision, the court also determined that an Arizona conviction for armed robbery is also not a violent felony under the Armed Career Criminal Act.
The full text of US v. Jones can be found here: