In the context of a criminal appeal, the Fourth Circuit addressed the elements of a New Jersey conviction for child endangerment under N.J. Stat. Ann. § 2C:24-4(a).  The court noted that the statute does not require any physical contact with the victim, and thus, does not match the federal generic definition of a crime of sexual abuse.  This decision could be helpful when analyzing whether a conviction under this statute qualifies as a sexual abuse of a minor aggravated felony for immigration purposes.

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