Wilson v. United States of America

In Wilson v. United States, the petitioner challenged his enhanced sentence under the Armed Career Criminal Act (ACCA). Wilson had prior convictions for Florida robbery, which were originally used to designate him as an armed career criminal. Relying on the Supreme Court’s decision in Johnson v. United States, which invalidated the ACCA’s residual clause as unconstitutionally vague, Wilson contended that Florida robbery no longer qualified as a violent felony under the remaining elements clause. On February 14, 2017, the United States Court of Appeals for the Eleventh Circuit reviewed the claim and determined that Florida robbery, as defined by state law, does not categorically require the use, attempted use, or threatened use of violent physical force against another person. Consequently, the court concluded that the prior convictions could not serve as ACCA predicates. The sentence was vacated, and the case was remanded for resentencing without the mandatory minimum enhancement.

The Eleventh Circuit held that Florida robbery is not categorically a violent felony under the ACCA’s elements clause. The court vacated the enhanced sentence and remanded the case for resentencing.

Whether a conviction for Florida robbery qualifies as a violent felony under the elements clause of the Armed Career Criminal Act after the residual clause was declared void for vagueness in Johnson v. United States.

The ruling directly impacted numerous federal inmates whose sentences had been enhanced based on Florida robbery predicates. It prompted sentence reductions and resentencings, and contributed to the broader post-Johnson reexamination of which state offenses can support federal armed career criminal designations.