Does the Tenth Circuit's analysis, which ignores the common law requirements of constructive-force robbery, conflict with the Court's adoption of the common-law definition of robbery in Stokeling?

Questions Presented for Review In Stokeling v. United States, 139 S.Ct. 544 (2019) this Court determined that the definition of robbery contained in the Armed Career Criminal Act (ACCA) found its roots in the common law definition and that same definition applies today. Contrary to Stokeling’s adoption of the common law definition of robbery, the Tenth Circuit now limits the application of the common law definition, finding it only applies to robberies employing actual force, and not necessarily to those involving constructive force. Under the common law, a threatened use of force to commit robbery must instill fear and that fear must be reasonable. New Mexico cases interpreting robbery reveal that New Mexico upholds robbery convictions: (1) when a defendant uses any amount of threatened force, including threats that do not frighten a victim; and (2) where the victim’s fear is not assessed for reasonableness. These cases mean that New Mexico robbery is not categorically a violent felony under the ACCA. Does the Tenth Circuit’s analysis, which ignores the common law requirements of constructive-force robbery, conflict with the Court’s adoption of the common-law definition of robbery in Stokeling? i