Does Illinois robbery categorically require the use of force and thereby qualify as a violent felony under the Armed Career Criminal Act?

QUESTIONS PRESENTED FOR REVIEW 1. Does Illinois robbery categorically require the use of force and thereby qualify as a violent felony under the Armed Career Criminal Act? (This Court has granted certiorari to consider essentially the same question, although the question arose in the context of Florida’s robbery statute. Stokeling v. United States, No. 17-5554, cert. granted April 2, 2018. The Court also has pending petitions raising this issue under the Illinois robbery statute. Klikno v. United States, No. 17-5018, cert. filed June 22, 2017; Van Sach v. United States, No. 17-8740, cert. filed May 31, 2018; and Shields v. United States, No. 17-9399, cert. filed June 12, 2018.) 2. The Seventh Circuit agrees that the Ilinois offense of attempt does not require the use of force. Nonetheless, it has ruled that, when the attempted offense is a violent felony, attempt is itself a violent felony, because that conclusion “makes sense.” Is attempt to commit a violent felony itself a violent felony, even though the elements of attempt do not categorically i require the use of force? (The Court has a pending petition raising this same issue. Hill v. United States, No. 18-5915, cert. filed August 28, 2018.) ii