Nethagani v. Mukasey, 532 F.3d 150 (2d Cir. Jul. 9, 2008) (New York conviction for first degree reckless endangerment [discharge of a firearm into the air] is a particularly serious crime for purposes of withholding of removal; a crime can be a particularly serious crime for purposes of withholding of removal even if it is not an aggravated felony).
jurisdiction:
Second Circuit