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.