Whether a state offense that includes as an element causing injury, but which also defines 'injury' broadly to include more than the 'physical pain or injury' described in Curtis Johnson, is categorically a 'crime of violence'

QUESTION PRESENTED This case concerns the United States Sentencing Guidelines’ “crime of violence” definition, specifically its “elements clause” (also called the “force clause”). U.S.S.G. § 4B1.2(a)(1). The Guidelines’ “elements clause” is, in all important ways, identical to the “elements clause” that appears in the Armed Career Criminal Act (“ACCA”), 18 U.S.C. § 924(e)(2)(B)(i), and which this Court interpreted in Curtis Johnson v. United States, 559 U.S. 133 (2010), as requiring a prior offense to include the use of “physical force,” that is, “force capable of causing physical pain or injury to another person.” (emphasis added). Because the Guidelines’ and ACCA’s “elements clauses” are functionally identical, and because the courts of appeals treat precedents governing the two provisions interchangeably, this Court should grant certiorari to address the following question: Whether a state offense that includes as an element causing injury, but which also defines “injury” broadly to include more than the “physical pain or injury” described in Curtis Johnson, is categorically a “crime of violence,” that is, an offense that “has as an element the use, attempted use, or threatened use of physical force against the person of another?” i