Can an assault conviction be a crime of violence under the Immigration and Nationality Act?

have held that the "intentional causation of injury does not necessarily involve the use of force," as it could be accomplished "not by physical force, but by guile, deception, or even deliberate omission." Chrzanoski v. Ashcroft, 327 F.3d 188, 193, 195 (2d Cir. 2003) (concluding that a Connecticut third-degree assault conviction was not a predicate "crime of violence" under the Immigration and Nationality Act). Likewise here, a conviction of second-degree burglary could be accomplished by "[c]aus[ing] physical injury" without using physical force.