Eleventh Circuit - Categorical Approach

United States v. Oliver, 962 F.3d 1311 (11th Cir. 2020). Georgia terroristic threats is a divisible statute and is a violent felony under § 924(e) when the threat predicating the conviction is “a threat to commit any crime of violence.”

United States v. Green, 969 F.3d 1194 (11th Cir. 2020). RICO conspiracy in violation of 18 U.S.C. § 1962(d), is not a crime of violence under § 924(c).

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