The Eight Circuit has determined that a Minnesota robbery conviction is a violent felony under the force clause of the Armed Career Criminal Act.

"Minn. Stat. § 609.24 minimally requires that a defendant 'threaten[] the imminent use of force' in order to either 'compel acquiescence' or 'to overcome the person’s resistance or powers of resistance . . . . While a threat on its own may not present the requisite degree of force, a statute that contains as an element a threat of violent force will. Minnesota’s express requirement that a defendant communicate a threat to 'overcome . . . resistance' or to 'compel acquiescence' necessarily implicates such violent force."

Given the similarity between the force clause and a crime of violence in the immigration context, this case could have persuasive force in immigration proceedings.

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