The Eighth Circuit has determined that an Iowa conviction going armed with intent is not a violent felony under the Armed Career Criminal Act (ACCA). The court noted that under the statute, “the movement and the intent are discrete elements, with no requirement that the movement be in furtherance of, or even in the direction of, commission of the crime.” Given the similarity between the definition of a violent felony under the ACCA and the definition of a crime of violence in immigration proceedings, this case is persuasive authority for immigration purposes.
The full text of United States v. Bennett can be found here: