The Eighth Circuit has determined that an Iowa conviction for committing willful injury - even the less serious offense that requires mere injury, as opposed to serious injury - is a crime of violence. “Committing willful injury in Iowa requires an unjustified ‘act’ that is ‘intended to cause serious injury.’ The fact that the statute requires an intent to cause harm to another person necessarily means that anyone who violates it has used ‘physical force against the person of another.’”
The full text U.S. v. Cungtion, Jr. can be found here: