Santos v. United States
In brief
The Supreme Court sent Santos’s case back to the Eleventh Circuit for another look, without deciding whether his Florida conviction is a violent felony under the ACCA.
- Where it stands
- Case remanded
Remanded · May 20, 2019
- What it’s about
- The Supreme Court vacated the Eleventh Circuit’s decision and sent the case back for reconsideration in light of the federal government’s position.
- Who it affects
- The order requires the Eleventh Circuit to reconsider Santos’s case but leaves unresolved whether his Florida conviction counts as a violent felony under the ACCA.
Summary: written with AI from the case record.

What it's about
The case concerns whether Santos’s Florida conviction for battery on a law enforcement officer counts as a “violent felony” under the Armed Career Criminal Act’s elements clause.
A district court concluded that Santos’s Florida conviction for battery on a law enforcement officer qualified as a “violent felony” under the Armed Career Criminal Act (ACCA). Santos then sought permission to challenge that conclusion, but the Eleventh Circuit denied his request.
The dispute centers on whether the ACCA’s elements clause—the rule about what a crime requires—treats Florida battery on a law enforcement officer as a violent felony.
Question presented
Whether the court of appeals erred in denying his request for a certificate of appealability to challenge the district court’s conclusion that his prior conviction for battery on a law enforcement officer under Florida law qualifies as a “violent felony” under the elements clause of the Armed Career Criminal Act of 1984 (ACCA), 18 U.S.C. 924(e)(2)(B)(i)?
What the Court decided
Holding
Motion to proceed in forma pauperis and petition for a writ of certiorari GRANTED. Judgment VACATED and case REMANDED for further consideration in light of the position asserted by the Solicitor General in his brief for the United States filed on March 21, 2019. Justice Alito, with whom Justice Thomas joins, dissenting. (Detached Opinion )
- Result
- Remanded
What's next
The Eleventh Circuit must reconsider the case in light of the Solicitor General’s position in the brief filed for the United States on March 21, 2019. The Supreme Court did not resolve the ACCA question.
Documents
Opinions
Key filings
Docket activity
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AI analysis generated: Case Briefing
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AI analysis generated: Decision Record
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More questions
- What was the stated reason for sending Santos’s case back?
- The Court ordered reconsideration in light of the position asserted by the Solicitor General in his brief for the United States filed on March 21, 2019.
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.