I guess this is getting a bit too technical for me.
As a road officer, we were taught to either know or know where to find the elements different crimes under Florida law. If we had the elements of a crime, we went ahead and charged the subject with a criminal violation. We later went to a "Pre-file conference" with an Assistant State Attorney to determine if the State felt they had sufficient evidence to proceed with a criminal prosecution. Sometimes, though we had a good arrest with all the elements documented, they would choose not to prosecute. So be it. It never occurred to me that if and when they chose not to prosecute, their actions automatically got renamed to a "violation of statute". In our stats we had a misdemeanor or felony arrest as the case may be, regardless.
But I guess I could buy that under some definition, Hillary may have violated statutes without having committed a criminal violation. If the best defense is that she broke the law but it wasn't technically a criminal violation, then so be it.
It would make a inspirational bumper sticker: "HILLARY! Violated Statutes But Not Criminal Violations"! Or "HILLARY! Broke The Law But Not A Criminal"!That should fire up the troops!