Ninth Circuit

AGGRAVATED FELONY - CRIME OF VIOLENCE
United States v. Harris, 572 F.3d 1065 (9th Cir. Jul. 24, 2009) (Nevada convictions for robbery and attempted robbery, in violation of Nevada Revised Statutes, 200.380 categorically qualified as "crimes of violence" under U.S.S.G. 4B1.2, for purposes of aggravated federal sentencing under the ACCA, since any offense punishable under that statute that does not qualify as a "robbery," does qualify as an "extortion."), following United States v. Becerril-Lopez, 541 F.3d 881, 892 (9th Cir.2008).

NOTE: In the aggravated felony context, this case may support an argument that the Nevada statute is not necessary a crime of violence, since "[t]he degree of force used is immaterial if it is used to compel acquiescence to the taking of or escaping with the property" N.R.S. 200.380.

EXTORTION - KIDNAPPING
United States v. Anderson, 989 F.2d 310 (9th Cir. 1993) (Washington: outlining generic definition of extortion by reference to 18 U.S.C. § 1951 federal definition for purposes of career offender sentencing enhancement).

Eleventh Circuit

AGGRAVATED FELONY " CRIME OF VIOLENCE " EXTORTIONATE CREDIT
Accardo v. U.S. Atty. Gen., 634 F.3d 1333 (11TH Cir. Mar. 10, 2011) (federal conviction for violation of 18 U.S.C. 892(a), extortionate extension of credit, is not categorically an aggravated felony crime of violence for immigration purposes, since the statute includes harm to a persons reputation).