United States v. Snype, Docket Nos. 04-3299-cr(L), 04-3551-cr(CON), 04-4985-cr(CON) (March 17, 2006) (found here)
18 U.S.C. § 3559(1) mandates a sentence of life imprisonment for a person convicted of a "serious violent felony" who has on two separate prior occasions been convicted of "serious violent felonies." 18 U.S.C. § 3559(c)(1), in turn, defines "serious violent felony" as including (among other offenses) robbery, as described in 18 U.S.C. §§ 2111, 2113 and 2118.
In Snype, the disrict court sentenced Snype to life imprisonment following his conviction for conspiracy to commit bank robbery and based on his prior separate New York State convictions for attempted second degree robbery, attempted first degree robbery, and first degree robbery (two counts). On appeal, the Second Circuit found that the elements of Snype's prior New York State robbery convictions "parallel those required to establish robbery" under federal law, and that there was therefore "no question that New York State convictions for first and second degree robbery by definition qualify as serious violent felonies under § 3559(c)(2)(F)(i)." Thus, the Second Circuit affirmed Snype's conviction. (It also bears noting that the Second Circuit found that the district court's findings concerning Snype's prior convictions did not violate Apprendi, notwithstanding an acknowledgement that the continued viability of the Almendarez-Torres exception to Apprendi "has been questioned.")