Whether federal voluntary manslaughter qualifies as a 'crime of violence' under 18 U.S.C. § 924(c)(3)(A)

QUESTION PRESENTED 18 U.S.C. § 924(c)(1)(A) prohibits the use of a firearm during and in relation to a federal “crime of violence.” “Crime of violence” is defined in § 924(c)(3)(A) as a felony offense that “has as an element the use, attempted use, or threatened use of physical force against the person or property of another.” Federal voluntary manslaughter is the unlawful killing of a human being without malice upon a sudden quarrel or heat of passion. It can be committed by reckless conduct, and it can be committed by a pregnant person’s prenatal conduct that results in the death of an infant after birth. The question presented is whether federal voluntary manslaughter qualifies as a “crime of violence” under § 924(c)(3)(A) where it can be committed by reckless conduct and by prenatal conduct before thete is another “person” within the meaning of federal law. i