United States v. Nobriga, ___ F.3d ___ (9th Cir. May 20, 2005) (per curiam) (Hawaii conviction of abuse of a family or household member, in violation of Haw. Rev. Stat. 709-906(A), did not invariably constitute a conviction of a misdemeanor crime of domestic violence, under 18 U.S.C. 921(a)(33)(A)(ii), because it did not necessarily require the use of violent force against the body of another individual, since it also prohibited refusal to comply with the lawful order of a police officer, but the "physically abuse" prong "requires, at a minimum, a reckless use of physical force. See State v. Eastman, 81 Hawai'i 131, 913 P.2d 57, 66 (Haw.1996); see also State v. Miller, 105 Hawai'i 394, 98 P.3d 265, 266 n.1 (Haw.Ct.App.2004). "Recklessness" is an adequate mens rea to establish a "violent" use of force. See, e .g., United States v. Grajeda-Ramirez, 348 F.3d 1123, 1125 (9th Cir.2003), cert. denied, --- U.S. ----, 125 S.Ct. 863, 160 L.Ed.2d 781 (2005); United States v. Ceron-Sanchez, 222 F.3d 1169, 1172-73 (9th Cir.2000). Nobriga's AFHM conviction was therefore for a "violent use of force."); but this decision may have been undermined by Leocal v Ashcroft, 125 S.Ct. 377 (2004); see Lara-Cazares v. Gonzales, ___ F.3d ___ (9th Cir. May 23, 2005); Lara-Cazares v. Gonzales, ___ F.3d ___ (9th Cir. May 23, 2005).