Whether Hobbs Act robbery categorically qualifies as a 'crime of violence' under the force clause of 18 U.S.C. § 924(c)

QUESTION PRESENTED FOR REVIEW Circuit courts have historically interpreted the Hobbs Act (18 U.S.C. § 1951(a)) to include threats to harm “intangible property” (economic harm). Some circuits have recognized that applying this definition to Hobbs Act robbery creates at least a theoretical possibility that it could be used in a way that does not come within the force clause of 18 U.S.C. § 924(c). Other circuits have concluded that Hobbs Act robbery by its own terms categorically requires the use of violent physical force. These circuits have ignored the fact that the broad definition of property has been used for many years in pattern jury instructions and in trials for Hobbs Act robbery around the country. Following this Court’s decision in United States v. Taylor, 142 S.Ct. 2015 (2022), it is clear that the “realistic probability” test does not apply to the Hobbs Act and that courts must decide what the elements of Hobbs Act robbery are when they apply the categorical approach under § 924(c), which the Tenth Circuit here did not do. Insofar as Hobbs Act robbery has historically been understood to reach threats to harm intangible property, is it categorically a “crime of violence” under the force clause of § 924(c)? i