Is grand theft from a person a violent crime?

However, particularly relevant is United States v. Wofford, 122 F.3d 787, 792 (9th Cir. 1997), where we held that grand theft from a person is a violent crime. That the crime involved "direct physical contact between the perpetrator and the victim" was significant to our determination. Id. at 793. Thus, we observed that "[w]hen [the thief] confronts the victim and seizes property from the victim's person, the criminal creates a serious risk of physical injury to another. . . . Even though the thief might sometimes . . . avoid immediate detection by his victim, he risks such a confrontation at every encounter." Id. at 794.⁸