Johnson v. United States

Summary

The Court held that Florida battery by intentionally touching another person, even slightly, does not satisfy the Armed Career Criminal Act's requirement that a predicate offense have as an element the use of physical force. In the context of a violent-felony definition, physical force means violent force capable of causing physical pain or injury, so Johnson's battery conviction could not support the enhancement. The Court reversed, set aside the sentence, and remanded for further proceedings, declining to permit consideration of the residual clause because the Government had disclaimed reliance on it. Justice Alito, dissenting and joined by Justice Thomas, would have treated the statute's reference to physical force as incorporating the common-law battery definition and affirmed.