What is the current state of the law on a categorical approach to sentencing enhancements under Section 3559(e)?

The categorical approach is distinct from the conduct-specific approach, under which courts "look[ ] to the facts of the specific [prior] case" to determine whether the conduct underlying a predicate conviction qualifies for a sentencing enhancement under the federal statute. United States v. Barrett , 903 F.3d 166, 173 n.3 (2d Cir. 2018). Here, the government argues that we should abandon the categorical approach applied in Rood in favor of the conduct-specific approach, because the language of 3559(e), which refers to the "conduct" of the defendant, requires it. However, Roods application of the categorical approach to 3559(e) has only been reinforced by subsequent precedent and remains binding on us.