The Ninth Circuit has determined that a Florida conviction for manslaughter does not qualify as a crime of violence under the federal sentencing guidelines because the statute does not require a minimal mens rea of at least recklessness. Given that the Ninth Circuit has defined a crime of violence in the immigration context to require a higher mens rea than recklessness, this decision will provide immigration attorneys with a great argument that a conviction under this statute is not a crime of violence aggravated felony.
The full text of United States v. Mendoza Padilla can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2016/08/16/15-10051.pdf