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).