The Eighth Circuit has concluded that a conviction for second-degree assault in Missouri, which forbids recklessly causing physical injury to another person by means of discharge of a firearm, is a crime of violence under the federal sentencing guidelines. The Court concluded that reckless conduct causing injury to another by use of a firearm constitutes a use of force under the guidelines. Given the similarity between the definition of a crime of violence under the guidelines and in the immigration context, this decision could have persuasive impact in immigration proceedings.
The full text of US v. Ramey can be found here: