Fernandez-Ruiz v. Gonzales,
410 F.3d 585 (9th Cir. June 1, 2005) (Arizona misdemeanor
conviction of domestic violence assault, in violation of Ariz.
Rev. Stat. § 13-1203(A)(1) or (2), which both require the
use, attempted use, or threatened use of physical force against
the person or property of another, therefore both qualify
as crimes of violence under 18 U.S.C. § 16(a); the offenses
were designated as a crimes of domestic violence under state
law pursuant to Ariz. Rev. Stat. § 12-3601 - even though the
state label is usually considered irrelevant because the state
conviction must qualify under the federal definition of a
ground of deportation), vacated on grant of rehearing en banc,
431 F.3d 1212 (9th Cir. Dec. 13, 2005).