If a statute has a causation-of-harm element, does it also necessarily have an element of violent force for purposes of classifying the crime as a violent crime?

QUESTION PRESENTED The Tenth Circuit held that Gerren Love’s prior Kansas aggravated-battery conviction, KSA § 21-5413(a)(1)(A), qualified as a crime of violence under the advisory guidelines’ clause, USSG § 4B1.2(a)(1). But the relevant section of Kansas’s aggravated-battery statute has a causation element, not an element of violent force. A jury need only find that the defendant caused a particular result, not that the defendant used, attempted to use, or threatened to use violent force against another person to commit the crime. At present, the courts of appeals are divided over whether a statute with a causation element necessarily has an element of violent force. This Court expressly left open this question in United States v. Castleman, 134 S.Ct. 1405, 1413 (2014). The question presented is: If a statute has a causation-of-harm element, does it also necessarily have an element of violent force for purposes of classifying the crime as a violent crime? i