First Circuit: US v. Garcia-Ortiz

As there is no realistically probable scenario in which Hobbs Act robbery could be accomplished without the use or threatened use of force, the offense is a valid predicate.

Harmless error on not revisiting sentence after revision to guidelines during pendency of appeal; original sentencing court understood its discretion to have terms run concurrently or in sequence.

http://media.ca1.uscourts.gov/pdf.opinions/16-1405P-01A.pdf