The Ninth Circuit has determined that an Ohio statute criminalizing assault on a police officer qualifies as a crime of violence. The court noted that knowledge is a sufficient mens reas for a crime of violence. The court also found that force sufficient to cause physical harm — even of minimal gravity or duration — is sufficient to qualify as a crime of violence.

The full text of United States v. Alvarez can be found here:

https://cdn.ca9.uscourts.gov/datastore/opinions/2023/02/16/21-50088.pdf

Comment