What is the current state of the law on section 924(c)(3)(B) of the Criminal Code?

In prior cases, this circuit has taken a categorical approach to section 924(c)(3)(B). In United States v. Springfield, 829 F.2d 860, 862-63 (9th Cir.1987), this court concluded that involuntary manslaughter is categorically a crime of violence under subsection (B) because by its nature it carries the risk of physical force. Similarly, this court ruled that conspiracy to rob is a subsection (B) crime and categorically is a crime of violence in United States v. Mendez, 992 F.2d 1488, 1490 (9th Cir.) ("This categorical approach is in contrast to the circumstantial or case-by-case method that requires the district court to inquire into the facts of the particular case."), cert. denied sub nom. Chavez v. United States, --- U.S. ----, 114 S.Ct. 262, 126 L.Ed.2d 214 (1993).