The Ninth Circuit has determined that a federal conviction for carjacking is a crime of violence under the federal sentencing guidelines.  "To be guilty of carjacking 'by intimidation,' the defendant must take a motor vehicle through conduct that would put an ordinary, reasonable person in fear of bodily harm, which necessarily entails the threatened use of violent physical force.  It is particularly clear that 'intimidation' in the federal carjacking statute requires a contemporaneous threat to use force that satisfies Johnson because the statute requires that the defendant act with “the intent to cause death or serious bodily harm.'”

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