Holding a substantive RICO conviction -- in which the underlying offense ple(a)d(ed) to or proven involved as an element the use of force -- to be a crime of violence is, under de facto modified categorical review, not plain error. Prior circuit precedent requiring two of the three underlying offenses to involve the use of force is dicta as to convictions with only one offense involving the use of force.
Sentence was not substantively unreasonable.