United States v. Werle, 877 F.3d 879 (9th Cir. Dec. 13, 2017) (Washington conviction of felony harassment, in violation of R.C.W. 9A.46.020(2)(b)(ii) [knowingly threaten to kill], is a crime of violence for illegal reentry sentencing purposes, even if the threat could be for an indeterminate time in the future and even if it may include a threat to use poison).

 

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