United States v. Watson

The Ninth Circuit denied defendants' 28 U.S.C. 2255 motions challenging the validity of their convictions for carrying a firearm during a crime of violence. The panel held that bank robbery "by force and violence, or by intimidation" is a crime of violence under the force clause of 18 U.S.C. 924(c). The panel reasoned that, because defendants' predicate offense, armed bank robbery, could not be based on conduct that involved less force than unarmed bank robbery requires, armed bank robbery qualifies as a crime of violence under section 924(c) as well. View "United States v. Watson" on Justia Law