The Eighth Circuit has determined that a Minnesota conviction for second-degree assault is a violent felony even though the statute does not require the defendant to cause actual bodily harm but only fear of bodily harm.  The Court also rejected a void-for-vagueness challenge to the force clause of the Armed Career Criminal Act.

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

http://media.ca8.uscourts.gov/opndir/18/07/171527P.pdf

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