Page:Denard Stokeling v. United States.pdf/32

Rh aggravated robbery statutes. The majority offers the single example of Florida aggravated robbery, noting that “Florida requires the same element of ‘force’ for both armed robbery and basic robbery.” Ibid. But while the majority accurately describes Florida law, there is scant reason to believe that a great many other States’ statutes would be similarly affected, because the effect that hewing to Johnson would have on Florida aggravated robbery stems from the idiosyncrasy that Florida aggravated robbery requires neither displaying a weapon nor threatening or inflicting bodily injury. The result for Florida aggravated robbery therefore sheds little light on what would happen to other aggravated-robbery statutes, the vast majority of which do (and did at the time of the ACCA’s enactment) appear to provide for convictions on such grounds—and whose validity as ACCA predicates would not necessarily turn on the question the Court faces today. The majority mistakes one anomalous result for a