(Univ. of Chicago Press ed. 1979) ("The lea[s]t touching of another’s per[s]on wilfully, or in anger, is a battery; for the law cannot draw the line between different degrees of violence, and therefore totally prohibits the fir[s]t and lowe[s]t [s]tage of it: every man’s per[s]on being [s] acred, and no other having a right to meddle with it, in any the [s]lighte[s]t manner.”) (alterations from Old English). 8 . We are not persuaded by respondent's reliance on a First Circuit case interpreting “physical force,” in a federal statute prohibiting possession of a firearm by one previously convicted of a crime of domestic violence, 18 U.S.C. § 922(g)(9), to include all physical force, regardless of its propensity to cause injury. See United States v. Nason, 269 F.3d 10, 16-18 (1st Cir.2001) (<HOLDING>). Nason addressed a Maine assault statute that
holding force to be an element of pre1994 amendment  111 which may be satisfied by proof of force or threat of force holding that expert testimony on what constitutes deadly physical force and whether the use of force was justified should have been excluded recognizing that an arrest requires either physical force  or where physical force is absent submission to the assertion of authority holding that congress intended the phrase physical force incorporated into  922g9 to encompass crimes characterized by the application of any physical force 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