United States v. Fierro-Reyna, __ F.3d __ (5th Cir. Sept. 28, 2006) (Texas conviction from 1979 for aggravated assault on a police officer, in violation of Penal Code 22.02(a)(2) (1974) [punishing simple assault on a police officer] is not a "crime of violence" for illegal re-entry sentencing purposes, since simple assault does not necessarily require use of force; state classification of assault as aggravated because it is committed against a police officer is irrelevant).
http://caselaw.lp.findlaw.com/data2/circs/5th/0551198cr0p.pdf