United States v. Michael Tinlin, 20 F.4th 426

Michael Tinlin pleaded guilty to conspiracy to distribute ≥500 grams of methamphetamine and to possession of a firearm in furtherance of a drug-trafficking offense.
The district court classified Tinlin as a career offender under USSG §4B1.1 based on two prior convictions for crimes of violence, producing an advisory range of 322–387 months.
One prior conviction was for Iowa domestic abuse assault, Iowa Code §§ 708.1(1), 708.2A(2)(c), which criminalizes assault against a domestic partner committed either with intent to inflict serious injury or by using/displaying a dangerous weapon.
Tinlin conceded the weapon-based variant would qualify as a crime of violence but argued the intent-to-inflict-serious-injury variant does not necessarily require the use, attempted use, or threatened use of physical force.
The Eighth Circuit relied on circuit precedent holding that Iowa assault with intent to inflict serious injury requires at least a threatened use of physical force, and therefore affirmed the career-offender classification and the resulting guideline calculation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Iowa domestic abuse assault with intent to inflict serious injury qualifies as a "crime of violence" under the guideline force clause	Tinlin: the intent-to-inflict-serious-injury alternative does not necessarily require use/attempted use/threatened use of physical force	Government: that variant necessarily involves at least a threatened use of physical force; circuit precedent supports qualification	The court held the offense is a crime of violence under the force clause and affirmed the guideline calculation

United States v. Quigley, 943 F.3d 390 (8th Cir. 2019) (holding Iowa assault with intent to inflict serious injury is a crime of violence under the guideline force clause)
United States v. McGee, 890 F.3d 730 (8th Cir. 2018) (holding an assault involving the display of a dangerous weapon qualifies under the force clause)