The Ninth Circuit has determined that an Arizona conviction for armed robbery is a theft-related aggravated felony. The court concluded that “to establish armed robbery, the state must prove that the defendant, while armed with a real or simulated deadly weapon, (1) took property from a person or his immediate presence (2) against that person’s will (3) using or threatening force with the coexistent intent to take the property.”
The full text of Guzman-Maldonado v. Garland can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/02/14/23-9.pdf