The Eighth Circuit has determined that a conviction for second-degree battery with a deadly weapon other than a firearm in Arkansas qualifies as a violent felony.  The court rejected the petitioner's argument that the infliction of injury does necessarily require the use of violent force.  Given the similarity between the definition of a violent felony and a crime of violence aggravated felony in the immigration context, this decision could have persuasive value in the immigration context.

The full text of U.S. v. Winston can be found here: