The Eighth Circuit has determined that an Arkansas conviction for third degree domestic battery is a violent felony under the Armed Career Criminal Act. The court determined that the statute is divisible, but subsection (a)(1), which requires the infliction of injury, meets the definition of a violent felony because the infliction of injury necessarily requires the use of violent force. Given the similar definition of a violent felony and crime of violence in the immigration context, this case may be persuasive in immigration proceedings.
The full text of US v. Moore can be found here: