Some Federal circuit courts have ruled that aliens can be deported for multiple DUI offenses, stating that under U.S. immigration law aliens can be removed from the United States for committing an "aggravated felony." An aggravated felony is a "crime of violence" in which the imprisonment term is at least 1 year. The Supreme Court clarified the issue somewhat in Leocal v. Ashcroft when it ruled that DUI convictions--absent a mens rea component (criminal intent to do harm) or with a mens rea of negligence--were not deportable offenses; however, the Court refused to address whether an offense with a mens rea of recklessness as to the use of force against another person or property of another might constitute a crime of violence under 18 U.S.C. section 16. By failing to address this issue, the Court did not decide whether felony reckless driving was a deportable offense, thus leaving significant confusion about which features of a DUI event make it a deportable offense. A potential split has developed among circuit courts about the classification of reckless driving, an offense closely related to DUI. The Supreme Court should next determine that intent to use force is required for a crime of violence. This would exclude both DUI offenses and a felony reckless driving offense from the category of crimes of violence. 210 footnotes