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statutepleafelonyprobationcommon law
felony

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Stokeling v. United States

Facts

In the early hours of July 27, 2015, Denard Stokeling was identified as a suspect in a burglary at a restaurant in Miami Beach, Florida. He had a criminal history with three prior felony convictions, including robbery. Stokeling was found in possession of a firearm and subsequently pleaded guilty to possessing a firearm as a felon. The probation office recommended he be sentenced as an armed career criminal under the ACCA, which led to the dispute over whether his prior robbery conviction qualified as a violent felony.

In the early hours of July 27, 2015, two people burgled the Tongue & Cheek restaurant in Miami Beach, Florida. Petitioner Denard Stokeling was an employee of the restaurant, and the Miami Beach Police identified him as a suspect based on surveillance video from the burglary and witness statements. After conducting a criminal background check, police learned that Stokeling had previously been convicted of three felonieshome invasion, kidnaping, and robbery.

Issue

Does the force required to commit robbery under Florida law qualify as 'physical force' for purposes of the Armed Career Criminal Act's elements clause?

This case requires us to decide whether a robbery offense that has as an element the use of force sufficient to overcome a victims resistance necessitates the use of 'physical force' within the meaning of the Armed Career Criminal Act (ACCA), 18 U. S. C. r4(e)(2)(B)(i).

Rule

Under the ACCA, a 'violent felony' is defined as any crime that has as an element the use, attempted use, or threatened use of physical force against another person.

ACCA defines 'violent felony' as 'any crime punishable by imprisonment for a term exceeding one year' that 'has as an element the use, attempted use, or threatened use of physical force against the person of another.'

Analysis

The Court analyzed the definition of 'physical force' in the context of the ACCA and determined that the force necessary to overcome a victim's resistance in a robbery is indeed physical force. The Court referenced the common law definition of robbery, which requires sufficient force to overcome resistance, and concluded that Florida's robbery statute aligns with this definition, thus qualifying as a violent felony under the ACCA.

Construing the language of the elements clause in light of the history of ACCA and our opinion in Johnson v. United States, we conclude that the elements clause encompasses robbery offenses that require the criminal to overcome the victims resistance.

Conclusion

The Supreme Court affirmed the Eleventh Circuit's decision, concluding that Stokeling's Florida robbery conviction qualifies as a violent felony under the ACCA.

We granted certiorari to address whether the 'force' required to commit robbery under Florida law qualifies as 'physical force' for purposes of the elements clause. We now affirm.

Who won?

The United States prevailed in the case, as the Supreme Court affirmed the lower court's ruling that Stokeling's robbery conviction met the criteria for a violent felony under the ACCA.

The Eleventh Circuit reversed. It held that the District Court erred in making its own factual determination about the level of violence involved in Stokelings particular robbery offense.

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