United States v. Torres-Villalobos, __ F.3d __, 2007 WL 528195 (8th Cir. Feb. 22, 2007) (Minnesota conviction for second-degree manslaughter, in violation of Minn. Stat. 609.205, was not a "crime of violence" under 18 U.S.C. 16 because the offense can be committed with mere reckless intent). http://caselaw.lp.findlaw.com/data2/circs/8th/061876p.pdf

People v. Dalerio, 144 Cal.App.4th 775 (Nov. 7, 2006) (California Penal Code 207(e), kidnapping, deceit plus constant physical presence was sufficient to find that defendant had used "force" to kidnap victim, since victim was a minor and was therefore unable to give consent to being taken.).