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).