Third Circuit - Categorical Approach

United States v. Bullock, 970 F.3d 210 (3d Cir. 2020). Assault of a federal employee involving a dangerous weapon or causing serious bodily injury, in violation of 18 U.S.C. § 111(b), is a crime of violence under §4B1.2.

United States v. Nasir, 982 F. 3d 144 (3d Cir. 2020) (en banc). The definition of “controlled substance offense” under §4B1.2(b) does not include inchoate offenses because they are listed only in the commentary of the guideline.

United States v. Croft, 987 F.3d 93 (4th Cir. 2021). South Carolina carjacking, which prohibits taking or attempting to take a motor vehicle “by force and violence or by intimidation while [a] person is operating the vehicle or while the person is in the vehicle,” is a violent felony under the Armed Career Criminal Act. South Carolina courts have “given every indication” that intimidation “require[s] the use, attempted use or threat of physical force against the person in the vehicle.”

United States v. Walker, 990 F.3d 316 (3d Cir. 2021). Attempted Hobbs Act robbery in violation of 18 U.S.C. § 1951(a) is a crime of violence under § 924(c).

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