Whether the Fourth Circuit erred in holding that the Violent Crimes in Aid of Racketeering (VICAR) statute is divisible

QUESTIONS PRESENTED 1. Whether the Fourth Circuit erred, in conflict with decisions of other circuits, in holding that for purposes of applying the categorical approach the Violent Crimes in Aid of Racketeering (VICAR) statute, 18 U.S.C. § 1959, is divisible into an indefinite number of distinct crimes based not on the structure of the statute but on how the government satisfied VICAR’s unlawfulness element. 2. Whether the Fourth Circuit erred in holding that “extreme recklessness” crimes necessarily involve a use of force against the person or property of another.