is “an aggressive and potentially violent act,” id. at 1246, requiring either the use physical force or violence, the threat of imminent force or violence coupled with an apparent ability to use that force or violence, or “some act that puts the victim in fear of death or great bodily harm.” Lockley, 632 F.3d at 1242; cf. Cano, 709 F.3d at 1054 (concluding that resisting an officer with violence constitutes a crime involving moral turpitude in part because it “involves the use or threat of physical force”). Finally, although the statute does not require the “use” of' a firearm or deadly weapon, the fact that a firearm or deadly weapon is “carried” during a robbery indicates its potential to be used by the defendant in furtherance of the robbery. Cf. Sosa-Martinez, 420 F.3d at 1342 (<HOLDING>). All of these factors combined lead us to the
holding that an intentional battery that involves the use of a deadly weapon constitutes a crime of moral turpitude holding that missouris reckless conduct statute establishes a crime involving moral turpitude holding that robbery under california law categorically qualified as a crime involving moral turpitude and noting precedent in this and other circuits that theft crimes are crimes involving moral turpitude recognizing the longstanding rule that crimes that have fraud as an element are categorically crimes involving moral turpitude and a court may not apply the modified categorical approach if the statute proscribes only conduct that involves moral turpitude holding that assault with a deadly weapon was not a crime involving moral turpitude