United States v. Nobriga, 408
F.3d 1178 (9th Cir. May 20, 2005) (per curiam) (Hawaii conviction
of abuse of a family or household member, in violation of
Haw. Rev. Stat. § 709-906(A), did not invariably constitute
a crime of domestic violence, under 18 U.S.C. § 921(a)(33)(A)(ii),
because it did not necessarily require the use of violent
force against the body of another individual, since it also
prohibited refusal to comply with the lawful order of a police
officer, but the "physically abuse" prong "requires,
at a minimum, a reckless use of physical force").