Does a controlled substance need to be a crime of violence?

¹⁴ We have distinguished controlled substance cases that say otherwise from cases concerning crimes of violence. Prakash v. Holder, 579 F.3d 1033, 1038 (9th Cir.2009) (explaining that the "statute that concerns us in this case, 18 U.S.C. 16(b)," which defines "crimes of violence," "does not itself contain a provision listing some inchoate crimes, such as attempt and conspiracy, to the exclusion of others. The legal principle that led to the results in these controlled substances cases does not apply here.").

¹⁵ United States v. Shumate, 329 F.3d 1026, 1030-31 (9th Cir.2003).

¹⁶ 74 F.3d 189, 190 (9th Cir.1996).