The Eighth Circuit has concluded that a felony conviction for domestic assault in Minnesota qualifies as a violent felony.  The statute of conviction requires the defendant to commit an act with intent to cause fear in another of immediate bodily harm or death.  The court determined that a conviction necessarily entails the threatened use of violent force.  Given the similarity between the definition of a violent felony in the sentencing context and a crime of violence in the immigration context, this decision may indicate that a conviction for domestic assault in Minnesota would also qualify as a crime of violence.

The full text of US v. Schaffer can be found here: