The Eighth Circuit has determined that a Missouri second-degree domestic assault conviction that criminalizes recklessly causing injury to a household member does not qualify as a crime of violence. The court noted that the statute encompassed reckless driving, which is outside the scope of a crime of violence under the federal sentencing guidelines. Given the similar definitions of a crime of violence under the sentencing guidelines and the immigration law, this case could have persuasive value in the immigration context.

The full text of US v. Harris can be found here: