Did the Court in Carter v. United States add an additional layer of proof to 18 U.S.C. § 2113(a) such that the government must now prove beyond a reasonable doubt that the defendant understood his actions were objectively intimidating?

QUESTION PRESENTED Did, as the First, Fourth, Sixth, Ninth and Tenth Circuits seem to believe, this Court in Carter v. United States, 530 U.S. 255 (2000), add an additional layer of proof to 18 U.S.C. § 2113(a) such that the government must now prove beyond a reasonable doubt that not only did a defendant engage in conduct that a reasonable person would perceive as intimidating, but also that the defendant understood that his actions were objectively intimidating? If this Court did not so hold and, as has historically been true, a conviction under § 2113(a) will be sustained even if the defendant was not aware his conduct would be perceived as intimidating by anyone, where the statutory definition of a crime of violence under 18 U.S.C. § 924(c)(8)(A) includes the language “against the person or property of another,” can the Ninth Circuit’s decision that § 2113(a) constitutes a crime of violence under § 924(c)(3)(A) be reconciled with this Court’s decision in Leocal v. Ashcroft, 543 U.S. 1 (2004) holding that where a definition of a crime of violence includes the narrowing language “against the person or property of another,” to constitute a crime of violence a conviction must necessarily establish that the defendant was more than negligent with respect to whether his intentional use of force could harm another? i