United
States v. Arnold, 58 F.3d 1117, 1122 n. 4 (6th Cir. July 13,
1995) (Tennessee conviction for assault with intent to commit
sexual battery is not categorically a "crime of violence"
for purposes of 18 U.S.C. § 922(g)(1) (felon with a firearm)
because the minimum conduct of the offense can be committed
through force or coercion).