Singh v. Ashcroft, 386 F.3d 1228
(9th Cir. Oct. 21, 2004) (Oregon conviction under Or. Rev.
Stat. § 166.065(1)(a)(A), punishing intentionally harassing
or annoying another person by subjecting that person to offensive
physical contact, is not a crime of violence, and therefore
not a crime of domestic violence for immigration purposes,
since the force required to commit the offense, including
spitting, is not necessarily "violent" force).