...United States v Begay, 934 F3d 1033, 1041 (CA 9, 2019) (holding, within the context of a charge under 18 USC 924(c)(3), that the offense no longer qualifies as a "crime of violence" under analog to § 16(b) and does not qualify as a "crime of violence" under analog to § 16(a)).
9. Kidnapping, in violation of 18 USC 1201(a...18 USC 16(a), and is therefore an "aggravated felony." 8 USC 1101(a)(43)(F). "Crime of violence" is defined in...18 USC 16(a) as "an offense that has as an element the use, attempted use, or threatened use of physical force against the person or property of another," and...