The Eleventh Circuit has determined that Georgia’s simple battery statute is divisible between offensive touching (not a crime of violence) and touching causing injury (a crime of violence). The court also declined to give credit to a state court order “clarifying” the petitioner’s sentence to be a probation-only sentence, finding that the sentence was clearly one that involved a suspended term of incarceration.
The full text of Talamantes v. Attorney General can be found here:
https://media.ca11.uscourts.gov/opinions/pub/files/201915080.pdf