Brief of the National Association of Criminal Defense Lawyers as Amicus Curiae in Support of Petitioner
Argument: The Armed Career Criminal Act (ACCA) applies only to violent robberies. Because the use of violent force is not an element of robbery under Florida law, Florida robbery is not a “violent felony” under the ACCA. The Act’s legislative history, like its text, reflects Congress’s intent to target only violent robbery in ACCA. The government’s proposed focus on whether the facts of particular cases present some potential risk of slight injury would impermissibly expand the reach of the Elements Clause beyond its text.