In the context of a criminal sentencing case, the Eighth Circuit has ruled that a conviction for second-degree assault in Minnesota qualifies as a violent felony. A violent felony is a crime that requires the use, attempted use, or threatened use of physical force. The court found that because assault in Minnesota requires an act with intent to cause fear in another of immediate bodily harm or death, by extension, the act must involve the threatened use of physical force.
Given the similarity between the definition of a violent felony and the definition of a crime of violence in the immigration context, this case may provide valuable insight into the immigration consequences of a conviction for second-degree assault in Minnesota.
The full text of United States v. Lindsey can be found here: