Summary

In Leocal, the Supreme Court determined that 18 U.S.C. § 16's analogous catchall provision, providing that an offense is a crime of violence if it "involves substantial risk that physical force against the person or property of another may be used in the course of committing the offense," id. § 16(b), "relates not to the general conduct or to the possibility that harm will result from a person's conduct, but to the risk that the use of physical force against another might be required in committing a crime."