In the context of a criminal sentencing hearing, the Eighth Circuit determined that a conviction for second degree battery in Arkansas may qualify as a crime of violence.  The statute is divisible, but subsection (a)(4) - which requires intentionally or knowingly, without legal justification, causing physical injury to a law enforcement officer, a firefighter, a correctional facility employee, a school employee, an elderly person, a young child, a state officer or employee, a healthcare provider, or incompetent - meets the definition of a crime of violence.  Given the similarity in the definition of a crime of violence in the sentencing context and a crime of violence in the immigration context, this ruling likely indicates the subsection at issue is a crime of violence for immigration purposes, too.

The full text of US v. Rice can be found here: http://media.ca8.uscourts.gov/opndir/16/02/143615P.pdf

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