Whether a non-generic offense is divisible under Descamps v. United States

QUESTION PRESENTED To decide whether a non-generic offense is divisible under Descamps v. United States, 133 S. Ct. 2276 (2013), does a sentencing court need to take a grammar-based approach or an elementbased approach? That is, does the court need to ask: qd) Whether a prosecutor could, as a grammatical matter, possibly write the indictment such that it describes a generic offense? or (2) Whether jury instructions would possibly require the jury to unanimously find elements that would amount to a generic offense? i