Tenth Circuit: United States v. Melgar-Cabrera

Federal statute providing for incarceration for murder with a firearm is a separate offense, not a sentencing enhancement, given post-Apprendi jurisprudence.

Statute requiring the element of physical force in the commission of a felony implies the requirement of violent force.

Offensive touching can be sufficient force for Hobbs Act robbery.

Indirect force can be a use of physical force under the statute.

https://www.ca10.uscourts.gov/opinions/16/16-2018.pdf