Both parts of 18 U.S.C. § 16 require physical force “against the person or property of another . . . .”[145] 

[145] 18 U.S.C. § § 16(a), 16(b) (emphasis supplied).

Fifth Circuit

AGGRAVATED FELONY - CRIME OF VIOLENCE - ROBBERY
United States v. Tellez-Martinez, 517 F.3d 813 (5th Cir. Feb. 19, 2008) (California conviction of robbery, in violation of Penal Code 211, constitutes a crime of violence for sentencing purposes, rejecting argument that the state conviction does not constitute a crime of violence because it may be violated not only by the use of force but also by threats to property: "Although Tellez maintains that a conviction under the California robbery statute is not a crime of violence because the statute criminalizes threats to property as well as persons, his assertion is based on a misunderstanding of the essential language of the statute defining robbery as a crime committed: (1) directly against the victim or in his presence; and (2) against his will. Like the Texas statute at issue in Santiesteban-Hernandez, the California robbery statute involves the misappropriation of property under circumstances involving danger to the person. 469 F.3d at 380. Regardless of how the robbery occurs, that danger is inherent in the criminal act. Thus, even when the statute is violated by placing the victim in fear of injury to property, the property has been misappropriated in circumstances "involving [immediate] danger to the person." Id. (alteration in original).").).

Ninth Circuit

AGGRAVATED FELONY " CRIME OF VIOLENCE " ROBBERY
United States v. Jones, 877 F.3d 884 (9th Cir. Dec. 15, 2017) (Arizona conviction for armed robbery, under A.R.S. 13-1904, is not a violent felony for purposes of the ACCA, because Arizona's armed robbery does not require the use of force), following United States v. Molinar, 876 F.3d 953 (9th Cir. 2017).

AGGRAVATED FELONY " CRIME OF VIOLENCE " ROBBERY United States v. Jones, 877 F.3d 884 (9th Cir. Dec. 15, 2017) (Arizona conviction for armed robbery, under A.R.S. 13-1904, is not a violent felony for purposes of the ACCA, because Arizona's armed robbery does not require the use of force), following United States v. Molinar, 876 F.3d 953 (9th Cir. 2017).

AGGRAVATED FELONY " CRIME OF VIOLENCE " ROBBERY
United States vs. Sanchez Molinar, 876 F.3d 953 (9th Cir. Nov. 29, 2017) (Arizona conviction for robbery, in violation of Ariz. Rev. Stat. 13-1904(A), which includes merely possessing a fake gun during the commission of a robbery without mentioning or brandishing it, is not a crime of violence for purposes of the ACCA because the minimum conduct necessary to commit the offense is not sufficiently violent for to qualify as a crime of violence under Johnson v. United States, 559 U.S. 133 (2010)).

AGGRAVATED FELONY " CRIME OF VIOLENCE " ROBBERY
United States vs. Sanchez Molinar, 876 F.3d 953 (9th Cir. Nov. 29, 2017) (Arizona conviction for robbery, in violation of Ariz. Rev. Stat. 13-1904(A), which includes merely possessing a fake gun during the commission of a robbery without mentioning or brandishing it, is not a crime of violence for purposes of the ACCA because the minimum conduct necessary to commit the offense is not sufficiently violent for to qualify as a crime of violence under Johnson v. United States, 559 U.S. 133 (2010)).

AGGRAVATED FELONY " CRIME OF VIOLENCE " ASSAULT WITH A DEADLY WEAPON
United States v. Jimenez-Arzate, ___ F.3d ___ (9th Cir. Mar. 30, 2015) (amending and superseding opinion denying rehearing en banc) (California conviction for violation of Penal Code 245(a)(1) is categorically a crime of violence for federal sentencing purposes, since United States v. Grajeda, which held that a conviction under section 245(a)(1) is categorically a crime of violence, is still good law even in light of People v. Aznavoleh, 210 Cal.App.4th 1181 (2012), and People v. Wyatt, 48 Cal.4th 776 (2010), which do not hold that assault with a deadly weapon may be committed with reckless intent; a defendant guilty of assault must be aware of the facts that would lead a reasonable person to realize that a battery would directly, naturally and probably result from his conduct. He may not be convicted based on facts he did not know but should have known. Wyatt, at 159 (quoting People v. Williams, 26 Cal.4th 779 (2001)).

AGGRAVATED FELONY - CRIME OF VIOLENCE - ARSON
Jordison v. Gonzales, 501 F.3d 1134 (9th Cir. Sept. 4, 2007) (California conviction of arson, in violation of Penal Code 452(c) ("recklessly set[ting] fire to . . . a structure or forest land"), was not a "crime of violence" under 18 U.S.C. section 16(b) for purposes of triggering deportation as an aggravated felony under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F), since offense may be committed by setting fire to ones own property).

AGGRAVATED FELONY - CRIME OF VIOLENCE - ARSON - SAFE HAVEN - CRIME OF VIOLENCE - OFFENSE MUST BE AGAINST PERSON OR PROPERTY OF ANOTHER
Jordison v. Keisler, 501 F.3d 1134 (9th Cir. Sept. 4, 2007, amended Oct. 30, 2007) (California conviction for "recklessly set[ting] fire to ... a structure or forest land" in violation of Penal Code 452(c) is not categorically an aggravated felony "crime of violence" for purposes of removal since the offense may be committed by burning the defendant's own land or structure whereas a crime of violence is one that involves violence or potential violence against the person or property of others).

Eleventh Circuit

AGGRAVATED FELONY " CRIME OF VIOLENCE " ASSAULT ON AN OFFICER
United States v. Palomino-Garcia, 606 F.3d 1317 (11th Cir. May 21, 2010) (Arizona conviction for violation of Ariz. Stat. 13-1204(A)(7), aggravated assault against a police officer, defined as any simple assault against a law enforcement agent, is not necessarily a crime of violence for illegal re-entry sentencing purposes since the identity of the victim as a police officer does not affect the level of force required to constitute a crime of violence).