The Eighth Circuit has determined that a conviction under South Carolina Code § 16-23-410 (pointing a firearm at another) requires the “threatened use of physical force against the person or property of another," and thus, qualifies as a crime of violence under 18 USC § 16(a).  The court recognized that the Ninth Circuit has recently determined that 18 USC § 16(b) is unconstitutionally vague, but declined to address the issue in the instant case.

The full text of Reyes-Soto v. Lynch can be found here: http://media.ca8.uscourts.gov/opndir/15/12/143797P.pdf

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