Whether robbery convictions for purposes of the career offender provision of the United States Sentencing Guidelines should be limited to only those that meet the common law definition of robbery as originally defined by Congress in 18 U.S.C. App. §1202(c)(8) (1982)

Question Presented for Review Expressed _in the Terms and Circumstances of the Case. In Stokeling v. United States, 139 S.Ct. 544 (2029), this Court reviewed whether Florida’s robbery statute required a level of force necessary to qualify as a crime of violence under the Armed Career Criminal Act’s (hereinafter ACCA) elements clause, 18 U.S.C. §924(e)(2)(B)(i). The Court held “‘physical force,’ or ‘force capable of causing physical pain or injury,’ includes the amount of force necessary to overcome a victim’s resistence.” /d. at 555 (citation ommitted). The majority in Stokeling relied on the fact that Congress used the common law definition of robbery in the original enactment of the ACCA and in its subsequent expansion in the elements clause. Utah’s robbery statute, U.C.A §76-6-301, penalizes conduct beyond that of common law robbery. Should robbery convictions for purposes of the career offender provision of the United States Sentencing Guidelines be limited to only those that meet the common law definition of robbery as originally defined by Congress in 18 U.S.C. App. §1202(c)(8) (1982)? 1 (b) List of all