Tran v. Gonzales, 414 F.3d 464 (3d Cir.
July 12, 2005) (Pennsylvania conviction of "reckless
burning or exploding," in violation of 18 Pa.C.S.A. §
3301(d)(2), did not constitute a crime of violence under 18
U.S.C. § 16(b), and was therefore not an aggravated felony
crime of violence under INA § 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F)
for purposes of removal, since the crime required only a reckless
mens rea, and involved no risk that the defendant would intentionally
use force in the commission of the crime).