The Eighth Circuit has determined that an Arkansas conviction for domestic battery in the third degree is divisible in light of the decision in Mathis v. United States. In addition, the first subsection, which requests the infliction of injury on the victim, is a crime of violence for federal sentencing purposes. The court rejected the argument that injury can be inflicted without the use of violent force. Given the similarity between the definition of a crime of violence in the sentencing context and in the immigration context, this case could have persuasive value in an immigration case.
The full text of US v. Starks can be found here: