Does our holding conflict with the definition of a crime of violence?

Nor does our holding conflict with the recent decision in Park v. INS, 252 F.3d 1018 (9th Cir. 2001). Park acknowledged, as do we, that recklessness is a sufficient mens rea for a "crime of violence." 252 F.3d at 1024. Park's assertion that "an intentional use of physical force is not required," 252 F.3d at 1025 fn.9 (emphasis in original), is perfectly compatible with our analysis -the "crime of violence " definitions do not require an intentional use of force, but they do require a volitional act. To use the language of mens rea, the crime need not be committed purposefully or knowingly, but it must be committed at least recklessly.