The Ninth Circuit has determined that a federal conviction for second-degree murder qualifies as a crime of violence. In so doing, it determined that “reckless indifference” is a higher mens rea than “ordinary recklessness.”
The full text of United States v. Begay can be found here:
https://cdn.ca9.uscourts.gov/datastore/opinions/2022/05/05/14-10080.pdf