United States v. Nobriga, ___ F.3d ___ , 2006 WL 3821413 (9th Cir. Dec. 29, 2006) (Hawaii conviction for Abuse of a Family or Household Member, in violation of Hawaii Revised Statutes 709-906(1), did not categorically involve the "violent use of force," as required under Armed Career Criminal Act, 18 U.S.C. 921(a)(33)(A)(ii), since the offense of conviction does not necessarily require a "violent use of force").

jurisdiction: 
Ninth Circuit

 

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