In a criminal sentencing case, the Eighth Circuit determined that an Iowa conviction for domestic abuse - strangulation is a crime of violence. "The elements of Domestic Abuse–Strangulation are:(1) committing a domestic assault in violation of Iowa Code § 708.1, and (2) knowingly causing impaired breathing or blood circulation by either means in the statute. Knowingly strangulating another is categorically capable of causing physical pain or injury to another person because it requires proof that the victim’s breathing or blood circulation was impaired by the defendant. The offense here includes the use of violent force as an element ‘since its impossible to cause bodily injury without using force capable of producing that result." Given the similarity between the definition of a crime of violence in the sentencing context and in the immigration context, this decision may have persuasive value in immigration cases.
The full text of United States v. Parrow can be found here: