Ninth Circuit has extended this definition of "physical force” to other generic offense provisions (though not the Section 924(c)(3) force clause), including 18 U.S.C. § 16(a) and U.S.S.G. § 2L1.2, both of which define “crime of violence” using language that is identical or essentially identical to the language used in the ACCA force clause and the Section 924(c)(3) force clause). The Court finds it appropriate to do the same here. 3 . The text of Section 924(c)(3)(A) does not explicitly require that there be an intentional use of physical force in order for a crime to constitute a "crime of violence.” Still, Wade cites Ninth Circuit authority holding that similar penalty-enhancing statutes implicitly require intent. See Fernandez-Ruiz v. Gonzales, 466 F.3d 1121, 1130 (9th Cir. 2006) (<HOLDING>), However, the Supreme Court recently held that
holding that those crimes with a mens rea of negligence or recklessness do not trigger the enhanced penalties mandated by the acca holding that one can be convicted of attempted manslaughter under the subsections of section 765205 that require intentional conduct but not under the subsection that only requires the mens rea of recklessness holding that bank robbery is a crime of violence because a defendants knowledge that his behavior is intimidating satisfies 924cs mens rea requirement holding that a mens rea of unlawfully in the indictment was sufficient because the indictment referenced the applicable statute which required a reckless mens rea holding that neither recklessness nor gross negligence is a sufficient mens rea to establish that a conviction is for a crime of violence under section 16