The Ninth Circuit has determined that a conviction for aggravated assault in Texas is categorically a crime of violence under the federal sentencing guidelines. The statute requires the infliction of serious bodily injury or the use or exhibition of a deadly weapon. The court rejected the argument that seriously bodily injury could be inflicted without the use of violence force, such as through the administration of poison. The court also rejected the assertion that a defendant could exhibit a deadly weapon without using it. Given the similarity between the definition of a crime of violence under the sentencing guidelines and a crime of violence in the immigration context, this decision will likely have persuasive value in the immigration context.
The full text of US v. Calvillo-Palacios can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2017/06/28/16-10039.pdf