Ninth Circuit: US v. Hans Elding

State assault with a deadly weapon statute is a valid predicate crime of violence, as the requirement that the victim's immediate fear of reasonable bodily harm implies a use or threatened use of physical force.

As state robbery statute can be violated with violence to property, it isn't a categorical predicate crime of violence, and it doesn't match the generic definitions of robbery and extortion.

Questions about advisory sentencing guidelines are addressed under the rule of lenity.

As there is no requirement that the force used be violent, the state extortion statute isn't a predicate crime of violence.

http://cdn.ca9.uscourts.gov/datastore/opinions/2018/06/08/16-10457.pdf