Hernandez v. Sessions

(1) Whether the U.S. Court of Appeals for the 9th Circuit erred in holding that the causation of bodily injury necessarily establishes that an offense is a "crime of violence" within the meaning of 18 U.S.C. § 16(a), even if the offense does not have as an element the use, attempted use or threatened use of any force; and (2) whether the 9th Circuit erred in holding that the California offense of criminal threats, California Penal Code " 422(a) " which requires a threat of bodily injury but not the use, attempted use or threatened use of any force " is a "crime of violence" within the meaning of 18 U.S.C. § 16(a).