Travis: Vehicular Flight is a "Crime of Violence"

In U.S. v. Travis, No. 13-10400 (April 4, 2014), relying on Sykes v. U.S., held that vehicle flight in violation of Fla. Stat. § 316.1935(1) constitutes a crime of violence for purposes of the career offender sentencing guideline. The Florida statute, like the one at issue in Sykes, required nothing more than using a vehicle to flee after an officer has ordered the driver to stop. The Court held that even though § 316.1935(1) violations do not involve high speeds or other reckless conduct, they are an inherently risky enterprise because they can end in violent confrontations between the offender and police. They therefore qualify as offenses presenting “a serious potential risk of physical injury to another.”