Decision date: 2005-07-05

Holding that Virginia conviction for involuntary manslaughter under Va. Code § 18.2-36 is not an aggravated felony crime of violence because the conviction's required element of general recklessness does connote recklessness as to whether force will be used.

Publication Status: Published

Case judge: Niemeyer, Shedd

Decision: Bejarano-Urrutia v. Gonzales, 413 F.3d 444 (4th Cir. 2005)