United States v. Parral-Dominguez, ___ F.3d ___, 2015 WL 4479530 (4th Cir. Jul. 23, 2015) (North Carolina conviction for discharging firearm into occupied building, under N.C.G.S.A. 14"34.1(a) (discharge a firearm into a structure while it is occupied, when the defendant had reasonable grounds to believe that the building might be occupied by one or more persons), N.C.G.S.A. 14"34.1(a), was not crime of violence for purposes of imposing a 16-level sentence enhancement under U.S.S.G. 2L1.2(b)(1)(A)(ii), since the state offense does not require that an offender use, attempt to use, or threaten to use force against another person as required by this Guidelines provision); accord, United States v. Narvaez"Gomez, 489 F.3d 970, 976"77 (9th Cir. 2007) (ruling that discharging a firearm at an occupied dwelling under California law is categorically not a crime of violence under 2L1.2, because it may be committed with purely reckless conduct toward another person); United States v. Jaimes"Jaimes, 406 F.3d 845, 850"51 (holding that discharging a firearm into a vehicle or building under Wisconsin law is not a crime of violence under 2L1.2, because the offense contains no element consistent with the use-of-force clause and does not even require that an occupant actually be present); United States v. Alfaro, 408 F.3d 204, 209 (5th Cir. 2005) (finding that shooting into an occupied dwelling under Virginia law is not a crime of violence under 2L1.2, because a defendant could commit the crime merely by shooting a gun at a building that happens to be occupied without actually shooting, attempting to shoot, or threatening to shoot another person); compare United States v. Quezada-Luna, 439 F.3d 403 (7th Cir. Mar. 3, 2006) (Illinois conviction of discharging a firearm at a building he or she knows or reasonably should know is occupied constitutes an aggravated felony crime of violence, under 18 U.S.C. 16(a), (b), 8 U.S.C. 1101(a)(43)(F) (use, attempted use, or threatened use of physical force against the person or property of another or substantial risk of it) (emphasis supplied), since discharging a firearm at the structure alone qualifies as a crime of violence against property); but see Jimenez-Gonzalez v. Ukase, 548 F.3d 557 (7th Cir. Nov. 21, 2008) (Indiana conviction of criminal recklessness did not qualify as crime of violence supporting aggravated felony-based removal).