arm movement and flight by an arrestee of the type that would violate the Massachusetts statute strikes us as more akin to escape than the failure to report that Chambers held not to be a violent felony. See Chambers, 129 S.Ct. at 691 (“The behavior that likely underlies a failure to report would seem less likely to involve a risk of physical harm than the less passive, more aggressive behavior underlying an escape from custody.”); Commonwealth v. Montoya, 73 Mass.App.Ct. 125, 130, 896 N.E.2d 638, 642 (2008) (construing § 32B to reach “a defendant’s flight where the circumstances of such flight expose his pursuers to a ‘substantial risk of bodily injury’ ” but not “mere flight on foot from arrest” (emphasis omitted)); see also United States v. Pratt, 568 F.3d 11, 22 (1st Cir.2009) (<HOLDING>). Because the two drug offenses and conviction
holding that burglary is violent felony holding prior to chambers that a walkaway escape is categorically a violent felony holding that an escape from custody under minnesota law is a crime of violence holding that escape from secure custody is a violent felony holding that escape is categorically a violent felony under the acca