Facilitation of Aggravated Robbery is a Violent Felony

U.S. v. Gloss, No. 10-5417 (6th Cir. Nov. 17, 2011) (published), http://www.ca6.uscourts.gov/opinions.pdf/11a0291p-06.pdf.

In this Armed Career Criminal Act case, the court held that facilitation of armed robbery under Tennessee law is a violent offense because it has as an element the use, attempted use, or threatened use of physical force against the person of another.  This is similar to the BIA's recent decision in Matter of Guerrero, 25 I&N Dec. 631 (BIA 2011).