The Ninth Circuit has amended its decision in Cornejo-Villagrana v. Sessions. In the amended opinion, the court recognized that Arizona’s misdemeanor domestic assault statute is divisible between intentional use of force and reckless use of force. However, the court determined that the record was clear that the petitioner had been convicted of a Class 1 misdemeanor, which required that his assault involve the intentional or knowing infliction of injury. Thus, the court declined to address whether the reckless use of force would be sufficient to constitute a crime of violence.
The amended opinion can be found here: