In the context of a criminal sentencing case, the Eighth Circuit has determined that a conviction for first-degree batter in Arkansas (Ark. Code. Ann. section 5-13-201) is a crime of violence.  The court noted that the statute is divisible, but that subsection (a)(1), which requires the infliction of serious physical injury through the use of a deadly weapon, requires the requisite violent force to be a crime of violence.

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