Page:Denard Stokeling v. United States.pdf/21

6 Court, cannot meet Johnson’s definition of physical force. As noted above, Florida robbery requires “force sufficient to overcome a victim’s resistance.” Robinson, 692 So. 2d, at 887. But that can mean essentially no force at all. See McCloud v. State, 335 So. 2d 257, 258 (Fla. 1976) (“Any degree of force suffices to convert larceny into a robbery”); Montsdoca, 84 Fla., at 86, 93 So., at 159 (“The degree of force used is immaterial”). For example, the force element of Florida robbery is satisfied by a pickpocket who attempts to pull free after the victim catches his arm. See Robinson, 692 So. 2d, at 887, n. 10 (citing Colby v. State, 46 Fla. 112, 113, 35 So. 189, 190 (1903)). Florida courts have held the same for a thief who pulls cash from a victim’s hand by “ ‘peel[ing] [his] fingers back,’ ” regardless of “[t]he fact that [the victim] did not put up greater resistance.” Sanders v. State, 769 So. 2d 506, 507 (Fla. App. 2000). The Government concedes, similarly, that a thief who grabs a bag from a victim’s shoulder also commits Florida robbery, so long as the victim instinctively holds on to the bag’s strap for a moment. See Tr. of Oral Arg. 32–34; see also Benitez-Saldana v. State, 67 So. 3d 320, 322–323 (Fla. App. 2011). And Stokeling points to at least one person who was convicted of Florida robbery after causing a bill to rip while pulling cash from a victim’s hand. See App. B to Brief for Petitioner.

While these acts can, of course, be accomplished with more than minimal force, they need not be. The thief who loosens an already loose grasp or (assuming the angle is right) tears the side of a $5 bill has hardly used any force at all. Nor does the thief who simply pulls his arm free from a store employee’s weak grasp or snatches a handbag onto which a victim fleetingly holds use “force capable of causing physical pain or injury to another person” in the sense that Johnson meant the phrase, because he does not use “a substantial degree of force” or “strong physical force.” See Johnson, 559 U. S., at 140. By providing that