Does Borden v. United States, 141 8. Ct. 1817 (2021), mean that the elements clause requires the specific intent to use, attempt to use, or threaten to use force, as the Eleventh, Tenth, and Third Circuits have found, or, as the Ninth Circuit concluded in this case, does Borden merely stand for the proposition that reckless crimes are outside the reach of the elements clause?

Question Presented Does Borden v. United States, 141 8. Ct. 1817 (2021), mean that the elements clause requires the specific intent to use, attempt to use, or threaten to use force, as the Eleventh, Tenth, and Third Circuits have found, or, as the Ninth Circuit concluded in this case, does Borden merely stand for the proposition that reckless crimes are outside the reach of the elements clause? iii Statement of