If the state or federal crime incorporated into an 18 U.S.C. § 1959(a)(3) conviction categorially does not meet the 18 U.S.C. § 924(c) definition of a 'crime of violence,' can the VICAR conviction itself nonetheless meet the 'crime of violence' definition?

QUESTION PRESENTED The federal VICAR assault statute criminalizes committing an assault “in violation of the laws of any State or the United States” for purposes of joining or advancing in a racketeering enterprise. 18 U.S.C. § 1959(a)(3). 18 U.S.C. § 924(c) criminalizes use or possession of a firearm in relation to a “crime of violence.” This petition presents the question: If the state or federal crime incorporated into an 18 U.S.C. § 1959(a)(3) conviction categorially does not meet the 18 U.S.C. § 924(c) definition of a “crime of violence,” can the VICAR conviction itself nonetheless meet the “crime of violence” definition?! ' This question is effectively the same question presented in the petition for certiorari pending before this Court in Thomas v. United States, No. 23-1168. ii LIST OF ALL DIRECTLY