The Ninth Circuit has determined that an Arizona conviction for a class one misdemeanor domestic violence offense is a crime of domestic violence. The court found that the statute is overbroad because it includes “recklessly causing any physical injury to another person.” However the court also determined that the statute is divisible. Because the petitioner was convicted of a class 1 misdemeanor, the Court deduced that he was convicted of intentionally or knowingly causing physical injury, which meets the definition of a crime of violence. Because the relationships in the statute are coextensive with those found in section 237(a)(2)(E)(i) of the INA, the petitioner's conviction qualifies as a crime of domestic violence.
The full text of Cornejo-Villagrana v. Sessions can be found here: