The following excerpt is from Windham v. Merkle, 163 F.3d 1092 (9th Cir. 1998):
"The type of harm is measured by whether the crime was violent in nature and whether the offense was directed at a person or at property." Cocio v. Bramlett, 872 F.2d 889, 892 (9th Cir.1989). Windham was convicted of murder, attempted murder, and assault with a firearm.
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