Esteras v. United States

On June 20, 2025, the U.S. Supreme Court ruled in Esteras v. United States, a case examining whether a petitioner's prior Ohio aggravated robbery conviction qualifies as a "violent felony" under the Armed Career Criminal Act (ACCA). Esteras challenged his enhanced 15-year mandatory minimum sentence, arguing that Ohio's statute is indivisible and broader than generic robbery, encompassing reckless conduct. The Sixth Circuit had previously applied the categorical approach and denied relief. The Supreme Court reversed, holding that because the Ohio statute criminalizes mere reckless force, it does not match the ACCA's elements clause requiring intentional, violent force. The ruling clarified the application of mens rea standards in ACCA predicate offense analysis.

The Supreme Court reversed the Sixth Circuit, holding 6-3 that Ohio aggravated robbery is not a violent felony under ACCA because its recklessness mens rea falls below the threshold of intentional conduct required by the elements clause. Esteras's enhanced sentence was vacated and remanded for resentencing.

Whether an Ohio aggravated robbery conviction, which can be committed with reckless infliction of harm, categorically qualifies as a "violent felony" under the Armed Career Criminal Act's elements clause, which requires purposeful or knowing use of violent physical force.

The decision narrowed the scope of ACCA sentencing enhancements, potentially affecting thousands of federal prisoners serving mandatory minimums based on reckless felony predicates. Sentencing reform advocates praised the ruling for restoring proportionality, while prosecutors warned it could lead to mass resentencing petitions. Legal scholars highlighted the decision's reinforcement of mens rea principles in recidivism statutes.