In United States v. Strickland, --- F.3d ---, No. 14-30168 (9th Cir. 2017), the Court held a conviction for third degree
robbery under Oregon law is not a violent felony for purposes of
the ACCA.
Under the ACCA's force clause, there must be violent force, i.e., force
capable of causing physical pain or injury to another person.
The Oregon statute, however, required only physical force, which is not necessarily violent.
Thus, under the categorical approach, the Oregon statute was not a predicate.
