The Eighth Circuit, addressing a conviction under Minn. Stat. § 609.50, subd. 2(2), determined that the conviction was not a crime of violence aggravated felony.  Although the statute prescribed conduct involving "force or violence," the state law definition of this phrase required less than the "violent force" required under the definition of a crime of violence.  Thus, the conviction did not qualify as an aggravated felony.

The full text of Ortiz v. Lynch can be found here: