This section has been intentionally left blank to allow for the inclusion of additional safe havens in the future.  We welcome your suggestions, and will be happy to share them with others via future editions of this book and its monthly updates on http://www.CriminalAndImmigrationLaw.com.

 

Sixth Circuit

SAFE HAVEN - INTERFERING WITH POLICE OFFICER
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").