Stokeling v. United States

Background

In 2015, two people burglarized the Tongue & Cheek restaurant in Miami Beach. Denard Stokeling, an employee, was identified and later pleaded guilty in federal court to being a felon in possession of a firearm. He had prior felony convictions, including a 1997 Florida robbery. The probation office sought a 15‑year enhancement under the Armed Career Criminal Act (ACCA); the District Court declined, the Eleventh Circuit reversed, and the Supreme Court reviewed the issue.

Reasoning

The central question was whether the "force" Florida robbery requires—force that overcomes a victim’s resistance—qualifies as ACCA’s "physical force." The Court examined ACCA’s history, common‑law robbery, and its prior decision in Johnson, which defined "physical force" as force capable of causing physical pain or injury. The majority concluded that overcoming resistance entails a physical contest and fits that definition, applied Florida precedent like Robinson, rejected Stokeling’s narrower reading, and affirmed the Eleventh Circuit.

Real world impact

Because Florida robbery requires force that overcomes resistance, those convictions qualify as ACCA predicates. That means people with three qualifying convictions, including Florida robbery, can face the ACCA’s 15‑year mandatory minimum when convicted of being a felon with a gun. The decision guides lower courts to treat similar state robbery laws as ACCA predicates and will affect federal sentencing where such convictions are present. This opinion resolves the merits of the dispute.

Dissents or concurrances

Justice Sotomayor, joined by three Justices, dissented. She argued that Johnson requires a higher degree of force and that Florida law can cover very slight force (for example, quick snatches or brief grabs), so treating those offenses as ACCA predicates wrongly expands the 15‑year enhancement to lesser offenders.