The Eleventh Circuit has vacated a felon-in-possession sentence and remanded for resentencing, holding that Florida attempted manslaughter is not a "crime of violence" under U.S.S.G. § 4B1.2(a). The court concluded that Florida attempt can be committed without the use of physical force, such as in an attempted manslaughter-by-procurement scenario.  This is a federal sentencing decision rather than an immigration case, but it applies the categorical approach used in removability analysis.

The full text of United States v. Johnson can be found here: https://media.ca11.uscourts.gov/opinions/pub/files/202114144.pdf

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