The Sixth Circuit has determined that a Michigan conviction for unarmed robbery is a crime of violence under the sentencing guidelines. The court noted that the minimum conduct punishable under the statute requires putting the victim in fear of physical injury, and thus, involves the threatened use of force. Given the similar definitions of a crime of violence in the sentencing guidelines and a crime of violence aggravated felony in the immigration context, this decision could have persuasive impact in immigration cases.

The full text of United States v. Fuller-Ragland can be found here: