United States v. Smith, 171 F.3d 617 (8th
Cir. Mar. 24, 1999) (Iowa conviction of misdemeanor assault,
under Iowa Code § 708.1(1), which may be committed by "[a]ny
act which is . . . intended to result in physical contact
which will be insulting or offensive to another," by
necessity, requires physical force to complete, and is thus
sufficient physical force to constitute a crime of violence
for purposes of 18 U.S.C. § 922(g) (felon with a firearm)).