Jobson v. Ashcroft,
326 F.3d 367 (2d Cir. Apr. 22, 2003) (New York conviction
of manslaughter in the second degree, under N.Y.P.L. § 125.15(1),
is not a crime of violence under 18 U.S.C. § 16(b) and thus
is not an aggravated felony under INA § 101(a)(43)(F), 8 U.S.C.
§ 1101(a)(43)(F), for deportation purposes, since the minimum
criminal conduct required to violate the statute does not
necessarily present a substantial risk that the defendant
will intentionally use physical force against the person or
property of another, because the scope of the law is broad;
passive conduct or omissions alone are sufficient for conviction).