The Eighth Circuit determined that the Arkansas statute criminalizing terroristic threats is divisible between making threats against a person and making threats against property, and then determined that the petitioner's conviction for threatening his girlfriend qualified as a violent felony under the Armed Career Criminal Act (ACCA). In addition, a second-degree battery conviction, under the non-deadly weapon subsection, qualifies as a violent felony because it requires the infliction of serious physical injury, thus mandating the use of physical force. Given the similar definitions of a violent felony under the ACCA and the definition of a crime of violence in the immigration context, this decision could have persuasive value in the immigration context.
The full text of United States v. Myers can be found here: