UNITED STATES OF AMERICA v. GEOFFREY THOMAS GATTIS
US Court of Appeals for the Fourth Circuit, Niemeyer, Dec. 4, 2017,
Federal Sentencing- Crime of Violence- North Carolina common law robbery conviction qualifies as a “crime of violence” under US Sentencing Guidelines

Pretty much all just LaFave quotes

Robbery – The generic crime of robbery involves “misappropriation of property under circumstances involving [immediate] danger to the person.” “It is the immediacy of the threat that escalates theft from extortion to robbery.”

Robbery – The distinct crime of “larceny from the person” thus becomes “robbery” in the generic sense only when the offender takes property by using force or by threatening immediate physical harm.

Robbery – The generic crime of robbery by force involves use of more than the minimal force necessary to take an item from the victim’s grasp

Theft vs. Robbery – Pickpocketing is theft from the person, rather than robbery, because “[t]aking the owner’s property by stealthily picking his pocket” does not involve the requisite degree of force against the owner.

Theft vs. Robbery – “[B]ut if the pickpocket or his confederate jostles the owner, or if the owner, catching the pickpocket in the act, struggles unsuccessfully to keep possession, the pickpocket’s crime becomes robbery.”