Monthly Archives: March 2018

Categorical Approach Update

Posted on March 8, 2018

United States v. Studhorse, __ F.3d __, 2018 WL 1122301 (9th Cir. Mar. 2, 2018): The Court held that attempted first-degree murder under Washington law (Wash. Rev. Code Ann. §§9A.28.020(1), 9A.32.030(1)) requires specific intent and has as an element an intentional, threatened, attempted, or actual use of force, so it qualifies as a crime of violence under 18 U.S.C. §16(a) and U.S.S.G. §4B1.2(a). United States v. Adkins, __ F.3d __, Case No. 15-10566 (9th Cir. Mar. 5, 2018): The Court held that the deletion of […]..