The Eighth Circuit has determined that an Iowa conviction for attempted murder is a crime of violence. In so doing, the court rejected the defendant's argument that the statute, which criminalizes any act that the defendant believes will set into motion a chain of events causing the death of another, was overbroad because it encompassed acts of omission. The court determined that even an act of omission under the statute involved the use of force. Given the similarity between the definition of a crime of violence in the sentencing context and the immigration context, this decision could have persuasive value in the immigration context.
The full text of United States v. Peeples can be found here: