Johnson v. United States (2009)
- Docket
- 08-6925
- Decided
- 2009-01-01
Summary
Question: 1) Was the Eleventh Circuit bound by the Florida Supreme Court's holding that its state battery law did not have, as an element, the "use or threatened use of physical force?" 2) Is a prior state conviction for battery in all cases a "violent felony?" Conclusion: Yes. No. The Supreme Court held that while the meaning of "physical force" in the ACCA is a question of federal law, not state law, the Court was bound by the Florida Supreme Court's interpretation of state law, including its determination of the elements of a Florida statute. Writing for the majority, Justice Antonin Scalia held that the Florida felony offense of battery by "actually and intentionally touching" another person does not have "as an element the use . . . of physical force against the person of another." The Court reasoned that within the context of the ACCA "physical force" means violent force, which rises beyond mere actual and intentional touching. Consequently, the Florida offense of battery does not constitute a "violent felony" under the ACCA. Justice Samuel A. Alito, joined by Justice Clarence Thomas, dissented. Justice Alito stated that the classic definition of the crime of battery is the "intentional application of unlawful force against the person of another." He argued that under such a definition, battery falls squarely within the plain language of the ACCA.