Unlawful possession or transfer of a weapon is not a crime of violence.

Evans v. Zych, No. 09-1094 (6th Cir. July 12, 2011).

In this criminal sentencing case, the Sixth Circuit held that a conviction under 28 U.S.C. 5861(d) and (e), receiving, possessing, or transferring an unregistered firearm is not a crime of violence under 924(c)(3).  Relevant to immigration law, 924(c)(3) is essentially identical to 18 USC 16.