Today, the Ninth Circuit decided United States v. Gutierrez, No. 16-35582:
The same panel decided in United States v. Werle, No. 16-30181 that "a Washington state conviction for felony harassment constitutes a crime of violence under the Federal Sentencing Guidelines."
The sole question presented by this appeal is whether the federal offense of carjacking is a "crime of violence" under 18 U.S.C. ยง 924(c). We hold that it is.Odd that the question can be asked seriously. All the circuits to consider the question have decided it the same way. See pages 5-6 for citations.
The same panel decided in United States v. Werle, No. 16-30181 that "a Washington state conviction for felony harassment constitutes a crime of violence under the Federal Sentencing Guidelines."

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