Second Circuit

FIRST DEGREE UNLAWFUL IMPRISONMENT - CRIME OF VIOLENCE
Dickson v. Ashcroft, 346 F.3d 44 (2d Cir. Sept. 9, 2003) (New York conviction of unlawful imprisonment in the first degree, in violation of N.Y. Penal Law § 135.10, with indeterminate sentence of one to three years, held not to be an aggravated felony crime of violence within the meaning of INA § 101(a)(43)(F), 8 U.S.C. § 1101(a)(43)(F), for deportation purposes, since the statute of conviction was divisible and the record of conviction did not establish that the particular conviction fell within the COV portion of the statute, since it was improper to consider the narrative statement of facts contained in the presentence report as part of the record of conviction).

Fifth Circuit

AGGRAVATED FELONY - KIDNAPPING - FALSE IMPRISONMENT
United States v. Iniguez-Barba, ___ F.3d ___, 485 F.3d 790 (5th Cir. April 25, 2007) (per curiam) (finding violation of a statute requiring as elements: (1) knowing removal or confinement; (2) substantial interference with the victim's liberty; and (3) force, threat, or fraud, or, if the victim is incompetent or under age thirteen, lack of consent from the person responsible for the general supervision of the victim's welfare, to be sufficient to qualify as "kidnapping" for purposes of meeting the "crime of violence" definition under U.S.S.G. 2L1.2; a "specific purpose" such as a desire for ransom, an intent to facilitate another felony or flight, etc. is not required; the court noted that just because a state labels an offense "false imprisonment" does not mean it is not "kidnapping" if it otherwise meets the elements listed above). See also, United States v. Gonzalez-Ramirez, 477 F.3d 310 (5th Cir.2007).

FALSE IMPRISONMENT - CRIME OF VIOLENCE
United States v. Stapleton, 440 F.3d 700 (5th Cir. Feb. 16, 2006) (Louisiana conviction for false imprisonment while armed with a dangerous weapon, in violation of La. Rev. Stat. Ann § 14:46.1(A) is a violent felony for purposes of the Armed Career Criminal Act, 18 U.S.C. § 924(e), because it necessarily presents a serious potential risk of physical injury to another).

Ninth Circuit

AGGRAVATED FELONY " CRIME OF VIOLENCE " 18 U.S.C. 16(b) " FALSE IMPRISONMENT
Barragan-Lopez v. Holder, 705 F.3d 1112 (9th Cir. Jan. 29, 2013) (California conviction of false imprisonment, in violation of California Penal Code 210.5 [false imprisonment under 236, for purposes of protection from arrest, which substantially increases the risk of harm to the victim], is categorically a crime of violence under 18 U.S.C. 16(b), because it involves a substantial risk that force may be used, and petitioner was thus removable as an aggravated felon) under INA 101(a)(43)(F), 8 U.S.C. 1101(A)(43)(f)). Note: This case did not address California Penal Code 236 by itself, but rather as enhanced under Penal Code 210.5, which includes the additional element of specific intent of avoid arrest, substantially increasing the risk of harm to the victim.

AGGRAVATED FELONY - CRIME OF VIOLENCE - FALSE IMPRISONMENT
United States v. Gonzalez-Perez, 472 F.3d 1158 (9th Cir. Jan. 10, 2007) (Florida conviction of false imprisonment under Florida law, did not constitute a crime of violence under U.S.S.G. 2L1.2(b)(1)(A)(ii), to warrant imposition of a 16-level sentence enhancement for illegal re-entry following deportation, because offense may be committed "secretly" without use of force). http://caselaw.lp.findlaw.com/data2/circs/9th/0510693p.pdf

FALSE IMPRISONMENT - CRIME OF VIOLENCE
United States v. Hernandez-Hernandez, 431 F.3d 1212 (9th Cir. Dec. 16, 2005) (California conviction of felony false imprisonment, in violation of Penal Code § 236, 237 constitutes a divisible statute, encompassing some offenses that constitute crimes of violence within the meaning of U.S.S.G. § 2L1.2(b)(1)(A)(ii), and some that do not; if defendant was or might have been convicted of committing false imprisonment by fraud or deceit, the conviction would not fall within the crime of violence portion of the divisible statute, for purposes of assessing a 16-level increase in base offense level for illegal re-entry).

FALSE IMPRISONMENT - CRIME OF VIOLENCE
United States v. Hernandez-Hernandez, 374 F.3d 808 (9th Cir. June 30, 2004) (California felony conviction of false imprisonment, in violation of Penal Code § 236, 237, is a divisible statute, as it may be committed by violence, menace, fraud or deceit; the record of conviction, which included by stipulation the statement of facts contained in a motion filed in the criminal case, established that the conviction occurred under the violence portion of the statute; conviction therefore constituted a crime of violence aggravated felony conviction, supporting a 16-level enhancement of sentence for illegal re-entry under U.S.S.G. § 2L1.2(b)(1)(A)(ii)).

Tenth Circuit

AGGRAVATED FELONY - CRIME OF VIOLENCE - FALSE IMPRISONMENT
United States v. Ruiz-Rodriguez, 494 F.3d 1273 (10th Cir. Aug. 1, 2007) (Nebraska conviction of first-degree false imprisonment, under Neb.Rev.St. 28-312(1), 28-314(1), was not categorically a crime of violence for purposes of imposing a 16-level sentence enhancement under U.S.S.G. 2L1.2(b)(1)(A)(ii) for unlawful reentry since a defendant could be convicted restricting a person's movement by deception (instead of force or threat) under terrorizing circumstances, which did not necessarily encompass an element of force).

Eleventh Circuit

FALSE IMPRISONMENT - CRIME OF VIOLENCE
Brooks v. Ashcroft, 283 F.3d 1268, 1273 n.5 (11th Cir. Mar. 1, 2002) (Florida conviction of false imprisonment under Fla. Stat. § 787.02 is a crime of violence under 18 U.S.C. § 16, and thus an aggravated felony under INA § 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F), for purposes of deportation).