1. Under the elements clause of 18 U.S.C. § 924(c)(3)(A), an offense qualifies as a "crime of violence" -- required for conviction under § 924(c)(1), prohibiting the use of a firearm during a "crime of violence" -- only if it "has as an element the use, attempted use, or threatened use of physical force . . . ." (Emphasis added). Hobbs Act robbery, in violation of 18 U.S.C. § 1951(a), is unlawfully taking property from someone "by means of . . . force, or violence, or fear of injury . . . to his person or property . . . ." Id. § 1951(b)(1) (emphases added).
"'Property' has a naturally broad and inclusive meaning. In its dictionary definitions and in common usage, 'property' comprehends anything of material value owned or possessed." Reiter v. Sonotone Corp., 442 U.S. 330, 338 (1979) (internal citation omitted). An asset's "intangible nature does not make it any less 'property.'" Carpenter v. United States, 484 U.S. 19, 25 (1987).
The first question presented is whether Hobbs Act robbery, which can be committed by causing the victim to fear economic loss ("injury") to an intangible asset ("property"), categorically qualifies as a crime of violence under § 924(c)'s elements clause, requiring the use of "physical force."

2. In Curtis Johnson v. United States, 559 U.S. 133, 140 (2010), the Court ruled that the "force" required in the elements clause of the Armed Career Criminal Act was "violent force," that is, "substantial," "extreme," and "strong physical force" "capable of causing physical pain or injury to another person." "Minor uses of force may not constitute 'violence' in the generic sense." United States v. Castleman, 134 S. Ct. 1405, 1412 (2014). For example, "a squeeze on the arm that causes a bruise" is "hard to describe . . . as violence," id. (internal quotation marks omitted); so too "relatively minor" "physical assaults" such as "pushing, grabbing, shoving, slapping, and hitting," id. at 1411–12.
Hobbs Act robbery is "based on [] New York law." Evans v. United States, 504 U.S. 255, 264 (1992). New York robbery may be committed by minor physical exertions such as a bump, see People v. Lee, 197 A.D.2d 378, 378 (N.Y. App. Div. 1993); a block, see People v. Bennett, 219 A.D.2d 570, 570 (N.Y. App. Div. 1995); or a brief tug-of-war over property, see People v. Safon, 166 A.D.2d 389, 892 (N.Y. App. Div. 1990).
The second question presented is whether Hobbs Act robbery, which like New York robbery can be committed by minor exertions of physical force, categorically qualifies as a crime of violence under § 924(c)'s elements clause, requiring the use of "violent force."

Whether Hobbs Act robbery, which can be committed by causing the victim to fear economic loss to an intangible asset, categorically qualifies as a crime of violence under 18 U.S.C. § 924(c)'s elements clause