The United States Court of Appeals for the Third Circuit held that in determining whether a prior crime qualified as a "crime of violence" for sentencing purposes under the United States Sentencing Guidelines, a sentencing court could inquire into the conduct underlying the prior offense to ascertain whether the conduct presented a "serious potential risk of harm to another."
United States v John, 936 F2d 764 (3d Cir 1991).
Barbara A. Fisfis,
Criminal Law - United States Sentencing Guidelines - Career Offender Status - Defining a "Crime of Violence",
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol30/iss4/12