The Eighth Circuit has affirmed that a federal conviction for voluntary manslaughter qualifies as a crime of violence because the mens rea of “depraved heart” or “extreme recklessness” is sufficient to establish a use of force against the person of another.

The full text of Brewer v. US can be found here:

http://media.ca8.uscourts.gov/opndir/24/01/223452P.pdf

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