United States v. Gagnon, 553 F.3d 1021 (6th Cir. Jan. 29, 2009) (federal conviction in violation of 18 U.S.C. 111, punishes activity less serious than simple assault; defendant who had spit at border patrol officers and forced himself to vomit was therefore guilty under 18 U.S.C. 111). Note: counsel can therefore argue that a conviction under this statute is not necessarily a crime of violence or a crime of moral turpitude. But see United States v. Chapman, 528 F.3d 1215, 1219 (9th Cir. 2008) (concluding that its construction of 111 "leaves no room for a conviction that does not involve at least some form of assault").