United States v. Bowers, No. 05-4908, 2005 WL 3527017 (3rd Cir. Dec. 27, 2005) (Link)
In Bowers, the Third Circuit wades into the circuit split pool concerning the question of whether an individual charged with being a felon in possession of a weapon (18 U.S.C. 922) has committed a crime of violence (for purposes of 18 U.S.C. 3156). (Bowers actually and directly dealt with a question of post-arrest detention.) Simply put, the Third Circuit joined the District of Columbia Circuit (United States v. Singleton, 182 F.3d 7 (D.C. Cir. 1999), Seventh Circuit (United States v. Lane, 252 F.3d 905 (7th Cir. 2001)) and Eleventh Circuit (United States v. Johnson, 399 F.3d 1297 (11th Cir. 2005)) in finding that the crime of felon in possession is not a crime of violence for purposes of 18 U.S.C. 3156, and rejected the Second Circuit's contrary conclusion (United States v. Dillard, 214 F.3d 88 (2d Cir. 2000)). As described by the Third Circuit, "we are unwilling to infer that a felon will use a gun violently merely because he owns it."