Rogers v. United States

(1) Whether bank robbery, 18 U.S.C. § 2113, which may be committed by unintentionally intimidating a victim or by presenting a teller with a demand note, has as an element "the use of physical force against the person or property of another" under 18 U.S.C. § 924(c)(3)(A); and (2) whether bank robbery by intimidation qualifies as a "crime of violence" under Section 924(c)"s elements clause, as the U.S. Court of Appeals for the 11th Circuit and many other circuits have held, although some other circuits have recently determined that similar state statutes do not qualify as "violent felonies" under the elements clause of the Armed Career Criminal Act.