Facts of the Case:
Curtis Johnson was convicted in a Florida federal district court for possession of ammunition by a convicted felon. He was sentenced under the Armed Career Criminal Act (ACCA) because the district court determined that his three earlier convictions constituted "violent felonies." Mr. Curtis appealed arguing that one of his prior convictions was for battery and the Florida Supreme Court had held the Florida battery law did not constitute a "violent felony."
On appeal, the U.S. Court of Appeals for the Eleventh Circuit held that Mr. Johnson's prior battery conviction under Florida law constituted a "violent felony" under the ACCA. The court reasoned that the force requirement of the definition for a "violent felony" was satisfied by the "touching or striking" element under the state battery law.
