Today, the Fifth Circuit addressed whether a conviction under Texas Penal Code 42.072 (stalking) qualifies as "force offense" type of crime of violence under the federal sentencing guidelines.  The court concluded that the offense, which criminalizes behavior that another person fears is threatening bodily injury, does not fall under the category of crimes of violence.  The court relied on prior Fifth Circuit precedent that determined that one can cause bodily injury without the use of attempted use of physical force and thus, the threat of bodily injury can occur in the absence of a threat to use physical force.  Though this case arose in the context of federal sentencing, the rationale could be persuasive for arguing that a stalking conviction is not a crime of violence for immigration purposes under 8 USC 16(a).  

You can find the complete decision in United States v. Rodriguez-Rodriguez here: