In the context of a criminal sentencing case, the Eighth Circuit has determined that a Minnesota conviction for terroristic threats does not qualify as a violent felony under the Armed Career Criminal Act (ACCA).  Given the similarity between the definition of a violent felony under the ACCA and the definition of a crime of violence in the immigration context, this decision could have persuasive value in the immigration context.

The full text of United States v. McFee can be found here: