The Eighth Circuit has vacated a felon-in-possession sentence enhanced based on prior felony convictions for forcibly assaulting federal officers, holding that a felony conviction under 18 U.S.C. § 111(a)(1) does not categorically require the violent physical force needed to qualify as a Sentencing Guidelines crime of violence.
The Court held that the statute's felony tier can be satisfied by mere intentional and offensive physical contact that a reasonable person would find objectionable, without any showing that the contact was capable of causing pain or injury, distinguishing the offense from other assault statutes requiring proof that the victim was placed in fear of imminent bodily harm. The Court remanded for resentencing under a corrected Guidelines range.
The full text of United States v. McIntosh can be found here: https://ecf.ca8.uscourts.gov/opndir/26/08/252394P.pdf