The Ninth Circuit determined that section 273a(a) of the California Penal Code is an indivisible statute; that is, a jury need not decide if a defendant engaged in intentional conduct (injurying a child) or negligent conduct (permitting a child's safety to be placed in danger).  Because negligent conduct is insufficient to qualify as a crime of violence, a conviction under this subsection is not a crime of violence aggravated felony.

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