On April 18, 2016, the Supreme Court decided Welch v. United States. Gregory Welch pleaded guilty to the charge of being a felon in possession of a firearm, in violation of federal law. Because Welch had three prior felony convictions, the district court determined that the Armed Career Criminal Act (ACCA) required that he be sentenced to a minimum of 15 years in prison. Welch appealed, arguing that his conviction for robbery in Florida state court did not qualify as a predicate offense for the purposes of ACCA because, at the time he was convicted, Florida state law allowed for a robbery conviction with a lower level of force than the federal law required to qualify as a predicate offense. The U.S. Court of Appeals for the Eleventh Circuit, however, affirmed the district court’s judgment, concluding that the minimum elements for conviction under the Florida law established a “serious risk of physical injury to another” and therefore qualified it as a predicate offense for purpos
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