United States v. Antonio Rice

Rice’s base offense level was calculated pursuant to USSG § 2K2.1(a)(3)(B), based on the assumption that he had previously committed a crime of violence. An offense is a “crime of violence” if it “has as an element the use, attempted use, or threatened use of physical force against the per*707son of another.” USSG § 4B1.2(a)(l). Relying on the definition of “physical-force” in the context of the Armed Career Criminal Act, Johnson v. United States, 559 U.S. 133, 130 S.Ct. 1265, 176 L.Ed.2d 1 (2010), we have said that “[p]hysical force” as used in § 4B1.2(a)(l) refers to “violent force.” United…