Robbery as a violent crime
Stokeling v. United States
In brief
The Supreme Court upheld the ruling that Stokeling’s Florida robbery conviction counts as a violent felony under the ACCA.
- Where it stands
- Decided
Decided 5-4 · January 15, 2019 · Opinion by Justice Thomas
- What it’s about
- The Supreme Court agreed with the Eleventh Circuit that Florida robbery qualifies as a “violent felony” under the Armed Career Criminal Act, a federal sentencing law, when it requires force to overcome a victim’s resistance—even if that force can be slight.
- Who it affects
- Stokeling’s Florida robbery conviction counts as an ACCA violent-felony conviction in his case.
Summary: written with AI from the case record.
What it's about
The Court upheld the ruling against Denard Stokeling.
Stokeling pleaded guilty in 2016 to possessing a firearm as a felon. The government and probation department sought a longer sentence under the ACCA, and he objected.
The ACCA sets a 15-year minimum sentence for certain people convicted of possessing a firearm after three qualifying prior convictions.
Question presented
Whether petitioner’s prior conviction for robbery, in violation of Fla. Stat. § 812.13 (1995), was a conviction for a “violent felony” under the Armed Career Criminal Act of 1984, 18 U.S.C. 924(e), because that offense “has as an element the use, attempted use, or threatened use of physical force against the person of another, ” 18 U.S.C. 924(e)(2)(B)(i).
What the Court decided
Holding
1. ACCA’s elements clause encompasses a robbery offense that requires the defendant to overcome the victim’s resistance. 2. Robbery under Florida law qualifies as an ACCA-predicate offense under the elements clause. The term “physical force” in ACCA encompasses the degree of force necessary to commit common-law robbery. And the Florida Supreme Court has made clear that the robbery statute requires “resistance by the victim that is overcome by the physical force of the offender.” Robinson v. State , 692 So. 2d 883, 886. 870, affirmed.
- Result
- Affirmed
The Court's reasoning
The Court said the ACCA covers the force needed for common-law robbery. Florida robbery requires physical force to overcome a victim’s resistance, so it meets that rule.
The vote
From the opinions
“Because the Court’s contrary ruling distorts Johnson, I respectfully dissent.”
What's next
The Supreme Court has finished the case, and the Eleventh Circuit’s ruling remains in place.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Show 2 moreShow fewer
Opinion added: opinion
Brief added: Questions Presented
More questions
- What did Justice Sotomayor argue?
- She argued that the ACCA requires more force than Florida robbery can require, so the conviction should not count.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.