Whether application of the residual clause of the definition of crime of violence' in U.S.S.G. §4B1.2(a)(2) constitutes procedural error in light of Johnson v. United States

QUESTION PRESENTED | 1. Whether application of the residual clause of the definition of “crime of violence” | in U.S.S.G. §4B1.2(a)(2), a clause identical to that of the residual clause of the | definition of “violent felony” in 18 U.S.C. §924(e)(2)(B)Gi), in enhancing a | t defendant’s guidelines sentencing range constitutes procedural error in light of this | Court’s decision in Johnson v. United States, __U.S.__, 135 S.Ct. 2551 (2015) | because the clause is hopelessly indeterminate and violates Congressional | directives to the Sentencing Commission? | |