State v. Walden
In State v. Walden, 183 Ariz. 595, 905 P.2d 974 (1995), the court acknowledged that Arizona's statutory definitions of sexual assault and kidnapping did not necessarily establish crimes of violence because both can be committed using deceit rather than force. Id.
But the court nonetheless found Walden's Hannah (State v. Hannah) prior convictions were violent crimes under former 13-703(F)(2) based on limiting jury instructions that had defined the lack of consent element for sexual assault to mean "'the victim was coerced by the immediate or threatened use of force against a person or property'" and the restraint element for kidnapping to "require a finding that the victim's movements were restricted 'by physical force or intimidation.'" 183 Ariz. at 617, 905 P.2d at 996.