The Ninth Circuit has partly granted a habeas petition filed by a man convicted of hiring a hit man to murder two business associates, holding that his solicitation convictions tied to those killings cannot stand because murder-for-hire resulting in death is not categorically a crime of violence under 18 U.S.C. § 373(a).
The Court held that while the death-results element of the murder-for-hire statute likely satisfies the physical force requirement, it lacks any mens rea requirement and can be satisfied by an accidental killing, meaning it does not categorically require the intentional use of force needed to qualify as a crime of violence.
The full text of United States v. Henrikson can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/07/15/23-2132.pdf