Case o' The Week: Ninth Nixes Extortion Contortions – Edling and "Crime of Violence" Under Guideline Definition

  Did Tony Soprano extort by threatening “physical injury” to his victim's iPad?  (Yeah, the Ninth doesn’t think so, either.)United States v. Edling, 2018 WL 2752208 (9thCir. June 8, 2018), decision available here.Players: Decision by Judge Watford, joined by C.J. Thomas and Judge Rawlinson.    Big win for AFPDs Cullen Macbeth, Amy Cleary, Cristen Thayer, the D. Nevada FPD, and the entire Ninth Circuit Johnson brain trust.  Facts: Edling pleaded guilty to being a felon in possession of a gun. Id. at *1. Under USSG § 4B1.1(a), a “crime of violence” increased his guideline range. Id.   One prior at issue was robbery, under Nevada Revised Statutes § 200.380. Id. That statute prohibits taking personal property from the person of another, by – among other means – force, violence, or fear of injury against the person or property. Id. at *3.   The district court held that offense…

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