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Rh App. 1989). It is worth noting that, in 1999, Florida enacted a separate “sudden snatching” statute that proscribes this latter category of conduct; under that statute, it is unnecessary to show either that the defendant “used any amount of force beyond that effort necessary to obtain possession of the money or other property” or that “[t]here was any resistance by the victim to the offender.” Fla. Stat. §812.131 (1999).

Thus, the application of the categorical approach to the Florida robbery statute is straightforward. Because the term “physical force” in ACCA encompasses the degree of force necessary to commit common-law robbery, and because Florida robbery requires that same degree of “force,” Florida robbery qualifies as an ACCA-predicate offense under the elements clause. Cf. Descamps v. United States, 570 U. S. 254, 261 (2013) (“If the relevant statute has the same elemen[t],” “then the prior conviction can serve as an ACCA predicate”).

In sum, “physical force,” or “force capable of causing physical pain or injury,” Johnson, 559 U. S., at 140, includes the amount of force necessary to overcome a victim’s resistance. Robbery under Florida law corresponds to that level of force and therefore qualifies as a “violent felony” under ACCA’s elements clause. For these reasons, we affirm the judgment of the Eleventh Circuit. It is so ordered.