. But see United States v. Persico, No. 10-CR-0147 (DLI), 2017 WL 3669554, at *3 (E.D.N.Y. Aug. 23, 2017) (concluding without analysis that the crime of extortionate extension of credit, in violation of 18 U.S.C. § 892, is not a predicate crime for a detention hearing under § 3142(f)(1)(A) because the maximum term of imprisonment is less than ten years). Def.'s Opp'n - ECF No. 7 at 8-9 (collecting cases, including cases discussing how a modifier at the end of a sentence applies to the entire series).
I realize that in reaching this conclusion I disagree with a handful of other district courts. See, e.g., United States v. Persico, 2017 WL 3669554, at *3 (E.D.N.Y. Aug. 23, 2017) ; United States v. Baldazo, 2012 WL 12947283, at *1 (N.D. Ind. Apr. 19, 2012) ; United States v. Madoff, 586 F.Supp.2d 240, 247 (S.D.N.Y. 2009) ; United States v. Chavez-Rivas, 536 F.Supp.2d 962, 965-66 (E.D. Wis. 2008). But these cases simply announced their assertion that the limitation applies to crimes of violence and did not explain how they reached that conclusion.