Vargas-Sarmiento v. US Dept Of Justice, __ F.3d __ (2d Cir. May 8, 2006) ("the physical force referenced in 16(b) includes any power, violence, or pressure directed against a person or thing [W]hen a perpetrator lures a person to voluntarily enter a room, only then to lock the door behind the person, the perpetrator has intentionally used physical force to commit the crime of imprisonment."), citing Dickson v. Ashcroft, 372 F.3d 44, 50 (2d Cir. 2003).
jurisdiction:
Second Circuit