Robert Serrano v. United States
I. Is a state robbery offense that includes as an element the requirement of overcoming victim resistance by use of force a violent felony under the elements clause of the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(i), if state appellate courts have specifically held that the amount of force used to overcome resistance is immaterial?
II. What amount of force satisfies this Court's definition of "physical force" in the elements clause of the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(i), in Johnson v. United States, 559 U.S. 133, 140 (2010), as violent force—that is, force capable of causing physical pain or injury to another person?
Whether a state robbery offense that includes as an element the requirement of overcoming victim resistance by use of force is a violent felony under the elements clause of the Armed Career Criminal Act, 18 U.S.C. § 924(e)(2)(B)(i), if state appellate courts have specifically held that the amount of force used to overcome resistance is immaterial