In Stokeling v United States, 586 U.S. ____ (2019), the U.S. Supreme Court held by a vote of 5-4 that the Armed Career Criminal Act’s (ACCA) elements clause encompasses a robbery offense that, like Florida’s law, requires the criminal to overcome the victim’s resistance. According to the majority, it was inconsequential that the force involved in the necklace snatching was minimal.
