underlying assaultive conduct. Compare United States v. Briley, 770 F.3d 267, 274-75 (4th Cir.2014) (discussing circuit split and holding that assault is not a required element of a § 111(a) misdemeanor or felony conviction) and United States v. Williams, 602 F.3d 313, 316-18 (5th Cir.2010) (discussing Sixth .and Ninth Circuit split and holding that "a misdemeanor conviction under § 111(a)(1) doés not require underlying assaultive conduct”) and United States v. Gagnon, 553 F.3d 1021, 1026 (6th Cir.2009), with United States v. Davis, 690 F.3d 127, 135 (2d Cir.2012) (“[F]or a defendant to be guilty of the misdemeanor of resisting arrest under Section 111(a), he necessarily must have committed common law simple assault.”) and United States v. Chapman, 528 F.3d 1215, 1221 (9th Cir.2008) (<HOLDING>). The Fifth Circuit has not yet had occasion to
holding that convictions under  111 require at least some form of assault holding that the defendants instate conduct must form an important or at least material element of proof in the plaintiffs case holding that under  111 the defendants knowledge of the official status of the victim is generally irrelevant holding that all convictions under wisconsin sexual assault statute were not per se convictions for crimes of violence recognizing the constitutionality of at least some amount of political gerrymandering