United States v. Michael Lee

For an offense to qualify as a "violent felony" under the ACCA's "elements clause," the least of the acts punished must have, as a necessary element, "the use, attempted use, or threatened use of physical force." 18 U.S.C. § 924(e)(2)(B)(i). In holding that Florida robbery is categorically a violent felony under the elements clause, the panel in United States v. Dowd , 451 F.3d 1244, 1255 (11th Cir. 2006), got it wrong. So did the panel in United States v. Lockley , 632 F.3d 1238, 1245 (11th Cir. 2011), which came to the same conclusion under the identical "elements clause" of the career…