3/2/18: Washington attempted murder is a crime of violence.

In United States v. Studhorse, --- F.3d ---, No. 16-30299 (9th Cir. 2018), the Court held that, under the categorical approach, attempted first degree murder under Washington law constitutes a “crime of violence” under 18 U.S.C. § 16(a) because it requires specific intent and has as an element an intentional, threatened, attempted, or actual use of force. Further, it is also a “crime of violence” under USSG § 4B1.2(a).