The Ninth Circuit has affirmed an Armed Career Criminal Act sentence, finding that the defendant's Oregon third-degree assault and strangulation convictions were violent felonies under the categorical approach and rejecting arguments that the assault statute's accomplice-liability provisions or its "extensively intertwined" doctrine swept in non-forceful conduct.
The full text of United States v. Patterson can be found here: https://cdn.ca9.uscourts.gov/datastore/opinions/2026/07/27/22-30088.pdf