Is a threatened use of physical force against the person of another an element of federal bank robbery, 18 U.S.C. §2113(a), so as to make it a crime of violence under USSG §4B1.2(a)(1)'s elements clause, when the Ninth Circuit holds that nothing more than a demand for money suffices to support conviction?

QUESTIONS PRESENTED 1. Is a threatened use of physical force against the person of another an element of federal bank robbery, 18 U.S.C. §2113(a), so as to make it a crime of violence under USSG §4B1.2(a)(1)’s elements clause, when the Ninth Circuit holds that nothing more than a demand for money suffices to support conviction? 2. Can a guideline violate the due process clause for a reason that is not grounded in the void-for-vagueness doctrine? -i