In U.S. v Batista, a Western District of Virginia judge hold that New York first degree robbery is divisible, that defendant does not have the burden to produce Shepard documents, and the offense does not satisfy the force clause.
In less uplifting news, say goodbye to the Holder Memo. Attorney General Jeff Sessions sent this memo on charging and sentencing policy to AUSAs this week, instructing them to charge and pursue the most serious charges.
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