REINALDO SANTOS
v.
UNITED STATES
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The Supreme Court vacated and remanded a case concerning whether a 1987 Florida battery conviction involving striking a law enforcement officer qualified as a "violent felony" under the Armed Career Criminal Act's definition requiring an element of physical force against another person. Justice Alito's dissent argued the conviction clearly met the statutory definition since the defendant struck an officer in the face, making the use of physical force an undisputed element of the offense.
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The Court grants, vacates, and remands in this case, apparently because it harbors doubt that petitioner's 1987 conviction under Florida law for battery on a law enforcement officer qualifies as a "violent felony" as defined by the Armed Career Criminal Act's elements clause, which covers a felony offense that "has as an element the use, attempted use, or threatened use of physical force against the person of another." 18 U. S. C. § 924(e)(2)(B)(i). I share no such doubt: As the case comes to us, it is undisputed that petitioner was convicted of battery on a law enforcement officer after he " 'struck [an] officer in the face using a closed fist.' " App. to Pet. for Cert. A-1, p. 11. See Fla. Stat. § 784.03(1)(a) (2018) (a person commits battery when he "[a]ctually and intentionally touches or strikes another person against the will of the other," among other things). Because the record makes "perfectly clear" that petitioner "was convicted of battery on a law enforcement officer by striking, which involves the use of physical force against the person of another," App. to Pet. for Cert. A-1, at 11, I would count the conviction as a "violent felony" under the elements clause and would therefore deny the petition. Mathis v. United States , 579 U. S. ----, ----, 136 S.Ct. 2243, 2267, 195 L.Ed.2d 604 (2016) (ALITO, J., dissenting).