The Ninth Circuit has determined that a conviction for second-degree murder under 18 U.S.C. §§ 1111 and 1153 is not a crime of violence under federal sentencing law because it can be committed recklessly (with a depraved heart mental state). Given the similar definitions of a crime of violence in the federal sentencing context and the immigration context, this case may have persuasive value in immigration litigation.
The full text of United State v. Begay can be found here:
http://cdn.ca9.uscourts.gov/datastore/opinions/2019/08/19/14-10080.pdf