United States
v. Treto-Martinez, 421 F.3d 1156 (10th Cir. Sept. 7, 2005)
(Kansas conviction of aggravated battery against a law enforcement
officer, in violation of K.S.A. 21-3414(a)(1)(C), is a crime
of violence for sentencing purposes; "[a]lthough not
all physical contact performed in a rude, insulting or angry
manner would rise to the level of physical force, we conclude
that all intentional physical contact with a deadly weapon
done in a rude, insulting or angry manner does constitute
physical force under § 2L1.2(b)(1)(A)").