Is federal bank robbery under 18 U.S.C. § 2113(a) a 'crime of violence' for purposes of enhanced sentencing under 18 U.S.C. § 924(c)?

The federal bank robbery statute, 18 U.S.C. § 2113(a), imposes criminal liability on “[w] hoever, by force and violence, or by intimidation, takes, or attempts to take, … or obtains or attempts to obtain by extortion any property or money … [from] any bank .” The so -called “elements clause” of 18 U.S.C. § 924(c ) provides for enhanced sentencing penalties where a defendant uses or carries a firearm in relation to a “crime of violence,” which is defined in relevant part as a felony that “ has as an element the use, attempted use, or threatened use of physical force against the person or property of another. ” 18 U.S.C. § 924(c)( 3)(A). It is undisputed that § 2113(a) bank robbery “by extortion” cannot satisfy § 924(c)’s elements clause on its own and according ly is not a “crime of violence” under § 924(c)(3)(A). The questions presented here , which are also presented in Armstrong v. United States, No. 24 -__ (petition filed July 1, 2025), are: 1. Is federal bank robbery in § 2113(a) indivisible, such that no form of bank robbery qualifies as a “crime of violence” for purposes of § 924(c)? 2. If the statute is divisible, did the Eleventh Circuit err in holding that attempted federal bank robbery nece ssarily includes “the use, attempted use, or threatened use of physica l force, ” such that it qualifies as a “crime of violence” for purposes of § 924(c)?