The Eighth Circuit has determined that an Arkansas kidnapping statute does not qualify as a violent felony under the Armed Career Criminal Act because it does require the use of physical force. The court also determined that the statute is indivisible. Because the definition of a violent felony is similar to definition of a crime of violence in the immigration law, this case may hav persuasive effect in immigration cases.
The full text of U.S. v. Coleman can be found here: