United States v. Bettcher, 2018 WL 6712268 (10th Cir. Dec. 21, 2018)

The Tenth Circuit held that Utah’s second-degree aggravated-assault offense qualifies as a “crime of violence” under the elements clause in the federal sentencing guidelines.  In doing so, it held that the Supreme Court’s decision in Voisine v. United States, 136 S. Ct. 2272 (2016), overrode Tenth Circuit precedent classifying reckless harm with negligent or accidental harm.