Precedents Cited

The judgment heavily references several key precedents to substantiate the court's decision:

• Johnson v. United States, 135 S. Ct. 2551 (2015): This Supreme Court decision invalidated the ACCA's residual clause, which allowed for prior convictions to qualify as violent felonies based on a residual definition. Post-Johnson, only prior felonies defined as violent under the ACCA's elements clause are applicable.
• TAYLOR v. UNITED STATES, 495 U.S. 575 (1990): Established the categorical approach, instructing courts to rely solely on statutory definitions rather than the underlying facts of prior convictions when determining their applicability under the ACCA.
• Stokeling v. United States, 139 S. Ct. 544 (2019): Reinforced that the force necessary to overcome a victim's resistance in robbery inherently qualifies as "violent" under the ACCA.
• Rehaif v. United States, 139 S. Ct. 2191 (2019): Clarified the interpretation of "knowingly" in the felon-in-possession statute, affecting post-conviction relief claims.

These precedents collectively support the court's stance on interpreting prior felony convictions within the ACCA framework, ensuring consistency and adherence to statutory definitions.

Legal Reasoning

The court's legal reasoning pivots on the interpretation of the ACCA's elements clause versus the residual clause. Post-Johnson, only prior felonies that explicitly meet the ACCA's definition of violent felonies can be considered. The elements clause defines a violent felony as one that "has as an element the use, attempted use, or threatened use of physical force against the person of another." Applying this to Indiana robbery, the court examined both potential methods of committing robbery under Indiana law:

• Robbery under the Force Clause: Defined as taking property by using or threatening physical force, which Indiana courts have consistently interpreted to require more than mere offensive touching. The cited Indiana cases demonstrate that sufficient force to overcome a victim's resistance constitutes violence.
• Robbery under the Fear Clause: Involves taking property by putting a person in fear of bodily injury. The court concluded that this also meets the elements clause as it involves the threatened use of physical force.

By adhering to the categorical approach and analyzing statutory definitions, the court determined that Indiana robbery, whether through force or fear, qualifies as a violent felony under the ACCA's elements clause. Additionally, the court dismissed Khamisi-El's attempt to incorporate the Rehaif decision, as it did not present newly discovered evidence or a new constitutional rule that would warrant amending the initial motion.

Impact

This judgment reinforces the stringent criteria for what constitutes a violent felony under the ACCA, especially in the wake of the Supreme Court's narrowing of its scope. By upholding Indiana robbery as a violent felony, the court ensures that individuals with similar convictions remain subject to the mandatory sentencing provisions of the ACCA. Furthermore, the denial of the amendment based on Rehaif sets a precedent for future post-conviction relief attempts, emphasizing the necessity for new claims to involve either newly discovered evidence or new constitutional interpretations.