Whether bank robbery (18 U.S.C. § 2113) has as an element 'the use...of physical force against the person or property of another,' under 18 U.S.C. § 924(c)(3)(A)

QUESTION PRESENTED Whether bank robbery (18 U.S.C. § 2113), which may be committed by unintentionally intimidating a victim or by presenting a teller with a demand note, has as an element “the use. . . of physical force against the person or property of another,” under 18 U.S.C. § 924(c)(3)(A). i