States, 2013 WL 1966062, at *3, 2013 U.S. Dist. LEXIS 68742, at *9-10 (D.Mass. May 14, 2013) (Zobel, J.). At the time of Duval’s sentencing, it was well-settled law in this circuit that a “touching” variant of common law battery fell within the meaning of use of “physical force” under the ACCA and similar statutes. See Nason, 269 F.3d at 21; Mangos, 134 F.3d at 464. To be sure, other circuits were split, but each decision was dependent on the wording of a particular state statute. Compare United States v. Griffith, 455 F.3d 1339, 1342 (11th Cir. 2006) (asserting that “[a] person cannot make physical contact-partieularly of an insulting or provoking nature — with another without exerting some level of physical force”); and United States v. Smith, 171 F.3d 617, 621 n. 2 (8th Cir.1999) (<HOLDING>); with United States v. Belless, 338 F.3d 1063,
recognizing that an arrest requires either physical force  or where physical force is absent submission to the assertion of authority holding that  2241a1 requires actual use of force meaning use of such physical force as is sufficient to overcome restrain or injure a person holding that kidnapping is a crime of violence which necessarily involves the threatened use of physical force under 18 usc  924 holding iowa common law touching assault met use of physical force required for enhancement under 18 usc  922g9 be cause any physical contact by necessity requires physical force to complete holding that congress intended the phrase physical force incorporated into  922g9 to encompass crimes characterized by the application of any physical force