Whether a state law robbery offense that extends to mere snatchings—involving only minimal physical contact with the victim—lacks the requisite degree of force to qualify as a 'violent felony' under the Act's elements clause

QUESTION PRESENTED In United States v. Walton, 881 F.3d 768 (9th Cir. 2018), the Ninth Circuit held that robbery offenses under Alabama law do not qualify as “violent felon[ies]” under the elements clause of the Armed Career Criminal Act (“ACCA” or the “Act”), because those offenses do not have “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). Without addressing that conflicting authority, the Eleventh Circuit held in the decision below that Alabama second-degree robbery does qualify as a violent felony under the Act’s elements clause. The question presented is: Whether a state law robbery offense that extends to mere only minimal physical contact with the victim—lacks the requisite degree of force to qualify as a “violent felony” under the Act’s elements clause. ii LIST OF ALL PARTIES All parties appear in the caption of the case on the cover page.