Ninth Circuit

AGGRAVATED FELONY - CRIME OF VIOLENCE - ARSON - SAFE HAVEN - CRIME OF VIOLENCE - OFFENSE MUST BE AGAINST PERSON OR PROPERTY OF ANOTHER
Jordison v. Keisler, 501 F.3d 1134 (9th Cir. Sept. 4, 2007, amended Oct. 30, 2007) (California conviction for "recklessly set[ting] fire to ... a structure or forest land" in violation of Penal Code 452(c) is not categorically an aggravated felony "crime of violence" for purposes of removal since the offense may be committed by burning the defendant's own land or structure whereas a crime of violence is one that involves violence or potential violence against the person or property of others).