Louis Gene Williams v. United States
AdministrativeLaw SocialSecurity Securities Immigration
Whether causing injury is synonymous with the use of physical force
QUESTIONS PRESENTED 1. A state crime is a “violent felony” (and therefore a predicate prior conviction under the Armed Career Criminal Act) if it “has 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)G). Texas defines its assaultive offenses (including aggravated assault and robbery) in terms of result—causing harm or injury—without referring to “force.” Is causing injury synonymous with the use of physical force? 2. Texas—like a small handful of other states—has expanded its definition of burglary to include the commission of any felony while trespassing, without requiring proof that the trespasser formed specific intent to commit that other crime. Is this a generic “burglary” offense for purposes of the Armed Career Criminal Act? i