The Ninth Circuit has determined that a Minnesota conviction for aiding and abetting simple robbery is a violent felony under the Armed Career Criminal Act (ACCA) because the statute requires the defendant to use the amount of force necessary to overcome a victim’s resistance. Given the similarity between the definition of a violent felony under the ACCA and a crime of violence in the immigration context, this decision could have persuasive value in immigration litigation.

The full text of Ward v. United States can be found here: