Whether the New York State offense of robbery satisfies the elements clause of the Armed Career Criminal Act

QUESTION PRESENTED Whether the New York State offense of robbery “has, as an element the use, attempted use, or threatened use of physical force against the person of another,” as required to satisfy the elements clause of the Armed Career Criminal Act, 18 U.S.C. §92.4(e)(2)(B)(i), a question that divides the circuits. i