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Tenth Circuit Announces That After Borden An Offense That Can Be Committed ‘Recklessly’ Is Not Categorically a ‘Crime of Violence’ Under § 924(c)’s Elements Clause
by Douglas Ankney
In consolidated cases on remand from the U.S. Supreme Court, the U.S. Court of Appeals for the Tenth Circuit held that defendants’ Violent Crimes in Aid of Racketeering (“VICAR”), 18 U.S.C. § 1959, convictions that were based on violations of Arizona and Utah statutes criminalizing assault with ...
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