Holding that (1) "physical force" in the term "crime of violence" in 18 U.S.C. § 16(a) connotes violent force capable of causing physical pain or injury and (2) Maryland second degree assault under Md. Code Ann., Crim. Law § 3-203 is not categorically a crime of violence because it does not require the use of violent force. Judge King dissented.

Date of Decision