Whether Hobbs Act robbery can be a categorical 'crime of violence' under 18 U.S.C. § 924(c)(3)(A) when pattern jury instructions extend it to causing fear of harm to intangible property

QUESTION PRESENTED In three circuits, pattern jury instructions extend Hobbs Act robbery (18 U.S.C. § 1951(b)) to an offense that can be committed by causing fear of harm to intangible property. At least one other circuit has a contrary set of instructions, while the First Circuit’s pattern instructions are ambiguous. Because fear of economic harm can be caused without the use or threat of violent force, does this split of authority preclude Hobbs Act robbery as a categorical “crime of violence” under the “force clause” of 18 U.S.C. § 924(c)(3)(A)?