Whether federal armed bank robbery under 18 U.S.C. § 2113(a) and (d) qualifies as a crime of violence under the elements clause of 18 U.S.C. § 924(c)(3)(A)

Question Presented for Review 1. Federal armed bank robbery under 18 U.S.C. § 2113(a) and (d) can be committed “by force and violence, or by intimidation... or... by extortion” and, therefore, does not require the specific intent to use, attempt to use, or threaten to use violent physical force. Numerous federal circuits interpret bank robbery to include such minimal, nonviolent conduct as a request for money. Does this offense nevertheless qualify as a crime of violence under the elements clause of 18 U.S.C. § 924(c)(3)(A)? i