United States v. Gonzalez-Chavez, __ F.3d __, 2005 WL 3196524 (5th Cir. Nov. 30, 2005) (aggravated battery under 784.045 of the Florida Statutes is a divisible statute, as the statute may be committed by any assault on a pregnant woman, including spitting, which does not involve the use, attempted use, or threatened use of force, and therefore may not be an aggravated felony crime of violence for sentencing purposes).
http://caselaw.lp.findlaw.com/data2/circs/5th/0440173cr0p.pdf