JOHNSON v. UNITED STATES

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Case Basics
Docket No. 
08-6925
Petitioner 
Curtis Darnell Johnson
Respondent 
United States
Advocates
(argued the cause for the petitioner)
(Assistant to the Solicitor General, Department of Justice, argued the cause for the respondent)
Term:
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.

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 
Decision: 7 votes for Johnson, 2 vote(s) against
Legal provision: Armed Career Criminal Act

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.

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JOHNSON v. UNITED STATES . The Oyez Project at IIT Chicago-Kent College of Law. 17 October 2014. <http://www.oyez.org/cases/2000-2009/2009/2009_08_6925>.
JOHNSON v. UNITED STATES , The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2000-2009/2009/2009_08_6925 (last visited October 17, 2014).
"JOHNSON v. UNITED STATES ," The Oyez Project at IIT Chicago-Kent College of Law, accessed October 17, 2014, http://www.oyez.org/cases/2000-2009/2009/2009_08_6925.