Castellanos v. Holder, ___ F.3d ___, ___, 2011 WL 3067948 (7th Cir. Jul. 20, 2011) (Illinois conviction for second offense domestic battery (intentionally causing bodily harm to family member), in violation of 720 ILL. COMP. STAT. 5/12"3.2(a)(1), constitutes "crime of violence" under 18 U.S.C. 16(a) and thus is an aggravated felony, under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F), because the statute unambiguously requires proving physical force: to sustain [a] conviction for domestic battery, the [S]tate had to prove that [the defendant] caused bodily harm, which means that it had as an element the use of physical force against the person of another. Upton, 512 F.3d at 45 (internal quotation marks and alterations omitted); accord LaGuerre, 526 F.3d at 1039.).