Stokeling v. United States

Denard Stokeling pleaded guilty to possessing a firearm as a convicted felon. The government sought a 15-year mandatory minimum sentence under the Armed Career Criminal Act (ACCA), arguing that Stokeling's prior Florida robbery conviction qualified as a "violent felony." The ACCA defines a violent felony as any crime that has as an element the use, attempted use, or threatened use of physical force against another. Stokeling contended that Florida robbery, which requires force sufficient to overcome victim resistance, did not meet this standard because it could be committed with minimal force. The Eleventh Circuit held that the offense qualified. The Supreme Court granted certiorari to resolve a circuit split on whether overcoming resistance necessitates violent physical force.

The Supreme Court affirmed the Eleventh Circuit in a 5-4 decision authored by Justice Clarence Thomas. The Court held that the force required to overcome a victim's physical resistance is inherently "violent" and falls within the ACCA's elements clause. It rejected the argument that de minimis force, such as purse snatching that overcomes resistance, is excluded. This resolved the split and upheld that Florida robbery is a violent felony for ACCA purposes.

Whether a state robbery offense that requires force sufficient to overcome a victim's resistance necessarily involves the use of "physical force" as defined by the elements clause of the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(i).

The ruling broadened the range of prior state offenses that trigger mandatory minimum sentences under the ACCA. It confirmed that even minimal force used to overcome victim resistance qualifies as violent physical force, strengthening prosecutorial tools in firearm possession cases. The decision was praised by law enforcement and criticized by sentencing reform advocates who argued it undermined efforts to reduce mass incarceration by expanding the definition of violent felonies.