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While Dimaya’s appeal was pending within the Ninth Circuit, the Supreme Court deemed the same clause in a separate 2015 case unconstitutional. This one was a part of the Armed Profession Criminal Act (ACCA), and defined a “violent felony” as any felony that “in any other case involves conduct that presents a severe potential risk of physical damage to another.” The Supreme Courtroom considered the clause “void for vagueness” under the fifth Amendment’s Due Course of Clause. Referring this other case, the Supreme Court held that the definition of “aggravated felonies” was also unconstitutionally imprecise [source: LLI].
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