The Eighth Circuit has determined that a conviction under South Carolina Code § 16-23-410 (pointing a firearm at another) requires the “threatened use of physical force against the person or property of another," and thus, qualifies as a crime of violence under 18 USC § 16(a).  The court recognized that the Ninth Circuit has recently determined that 18 USC § 16(b) is unconstitutionally vague, but declined to address the issue in the instant case.

The full text of Reyes-Soto v. Lynch can be found here: