In a published decision the Eleventh Circuit determined that a felony conviction in Georgia for obstruction qualified as a violent felony under the Armed Career Criminal Act (ACCA).  Georgia’s felony obstruction statute applies only to those who obstruct a law enforcement officer “by offering or doing violence” to the officer’s person.  This includes the attempted use of physical force by “pushing, struggling, kicking and flailing arms and legs."  Thus, it has as an element the use, attempted use, or threatened use of physical force against the person of another.  Given the similar language in the ACCA's violent felony definition and a crime of violence under 18 USC 16(a), this conviction likely qualifies as a crime of violence for immigration purposes, too.

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