The Fourth Circuit has determined that a conviction under 18 USC 1361 for damaging government property is not a crime of violence. The court found the statute does necessarily require violent force to be used against the property. Noting that the damage had to exceed a specific amount to sustain a conviction, the court concluded that “[t]he amount of damage to property, while defining felonious conduct under Section 1361, does not necessarily correlate with the type of the force employed.'“

The full text of US v. Melaku can be found here:

https://www.ca4.uscourts.gov/opinions/216122.P.pdf

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