United States v. Pimental-Flores, 339 F.3d 959 (9th Cir. August 11, 2003) (Washington conviction of third degree assault in violation of court order, under Rev. Code of Washington 26.50.110(4) may fail to trigger a 16-level illegal reentry sentence enhancement, as a crime of violence under U.S.S.G. 2L1.2 (2001), because the statute proscribes merely negligent assault).
jurisdiction:
Ninth Circuit