Brieva-Perez v. Gonzales, 482 F.3d 356 (5th Cir. Mar 19, 2007) (Texas violation of Penal Code 31.07(a), unauthorized use of a vehicle is a "crime of violence" and thus an "aggravated felony").



Note: The Fifth Circuit conceded that the "joyriding" involved no actual use of force. The Fifth Circuit reasoned, however, that joyriding carries a "substantial risk" that the vehicle might be broken into, stripped, or vandalized, or that it might become involved in an accident, resulting not only in damage to vehicle and other property, but in personal injuries to innocent victims as well.