Should this Court accept review to resolve the conflicting 'intimidation' interpretations the Circuits have given the federal bank robbery statute?

Question Presented For Review The Fourth, Fifth, Ninth, and Eleventh Circuits broadly interpret “intimidation” as used in the federal bank robbery statute for sufficiency purposes, affirming convictions for non-violent conduct that does not involve the use, attempted use, or threats of violent physical force. Yet, when applying the crime of violence categorical analysis, these same circuits find “intimidation” always necessarily involves the use, attempted use, or threats of violent force. Should this Court accept review to resolve the conflicting “intimidation” interpretations the Circuits have given the federal bank robbery statute? ii