The Eighth Circuit has determined that although the language of the Iowa statute criminalizing assault on a peace officer contains alternatives which lack a force element, the petitioner had not identified any case where the statute was applied in a way that did not involve at least the threatened use of physical force.

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

https://ecf.ca8.uscourts.gov/opndir/22/08/212369P.pdf

Comment