The analysis of whether the offense is against the person or property of another appears to be the same as for questions arising under 18 U.S.C. § 16(a).  See § 19.39, supra.

 

Fifth Circuit

AGGRAVATED FELONY - CRIME OF VIOLENCE - JOYRIDING
Brieva-Perez v. Gonzales, 482 F.3d 356 (5th Cir. Mar 19, 2007) (Texas violation of Penal Code 31.07(a), unauthorized use of a vehicle is a "crime of violence" and thus an "aggravated felony").

Note: The Fifth Circuit conceded that the "joyriding" involved no actual use of force. The Fifth Circuit reasoned, however, that joyriding carries a "substantial risk" that the vehicle might be broken into, stripped, or vandalized, or that it might become involved in an accident, resulting not only in damage to vehicle and other property, but in personal injuries to innocent victims as well.