Stokeling’s suggested definition of “physical force”—force “reasonably expected to cause pain or injury”—is inconsistent with the degree of force necessary to commit robbery at common law. Moreover, the Court declined to adopt this standard in Johnson. Stokeling’s proposal would prove exceedingly difficult to apply, would impose yet another indeterminable line-drawing exercise on the lower courts, and is not supported by United States v. Castleman, 572 U. S. 157.
Robbery under Florida law qualifies as an ACCA-predicate offense under the elements clause. The term “physical force” in ACCA encompasses the degree of force necessary to commit common-law robbery. And the Florida Supreme Court has made clear that the robbery statute requires “resistance by the victim that is overcome by the physical force of the offender.” Robinson v. State, 692 So. 2d 883, 886.
The slightest use of force can convert a relatively minor offense into a very serious one. A classic example is a shoplifting in which the shoplifter pushes the security guard on the way out of the store. Shoplifting is generally an offense that is punished by a fine and/or probation, but not incarceration. A robbery in New Jersey requires at least five years in prison with four and one-half years of parole ineligibility.