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PA Terroristic Threat Not Categorically a 2L1.2 COV Because It Doesn't Necessarily Require Physical Force

United States v. Ortiz-Gomez, No. 08-40292 (5th Cir. Mar. 10, 2008) (Davis, Smith, Owen)The Pennsylvania statute concerning "terroristic threats" criminalizes a variety of vexatious acts, including threats to commit a "crime of violence." Although Pennsylvania law isn't entirely clear on what constitutes a "crime of violence," the term includes arson. And arson, as defined in Pennsylvania,

Full post as published by Fifth Circuit Blog on March 13, 2009 (boomark / email).