U.S. v. Enoch

Dist. Ct. did not err in finding that defendant’s conviction for robbing person having custody of property belonging to U.S. under section 18 USC section 2114(a) qualified as “crime of violence” for purposes of supporting his conviction on brandishing firearm in relation to crime of violence under 18 USC section 924(c)(1)(A)(ii). Second part of section 2114(a), i.e., “robs or attempts to rob any such person…of money…and in effecting such robbery did put life of said person in jeopardy by use of dangerous weapon,” which was at issue in defendant’s guilty plea, contemplates force that is capable of causing injury, and therefore qualified as crime of violence.