When evaluating whether a state-law offense satisfies the Armed Career Criminal Act's definition of a 'violent felony,' 18 U.S.C. § 924(e)(2)(B), federal courts often have to interpret and apply state court decisions. Where state-law sources conflict with one another, does the ACCA's 'demand for certainty' constrain a federal court's interpretation of state criminal law?

QUESTIONS PRESENTED 1. When evaluating whether a state-law offense satisfies the Armed Career Criminal Act’s definition of a “violent felony,” 18 U.S.C. § 924(e)(2)(B), federal courts often have to interpret and apply state court decisions. Where state-law sources conflict with one another, does the ACCA’s “demand for certainty” constrain a federal court’s interpretation of state criminal law? 2.Mr. Lipscomb was previously convicted of robbery under Texas Penal Code § 29.02. That statute allows conviction when a thief recklessly causes someone to suffer injury or causes someone to fear imminent bodily injury. Does Texas simple robbery 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)@)? 3. Mr. Lipscomb was previously convicted of burglary under Texas Penal Code § 30.02(a). That statute allows conviction where a trespasser commits any “felony, theft, or assault” inside the premises. Many of those offenses allow conviction with a mens rea of recklessness, negligence, or even strict liability. Is Texas Penal Code § 30.02(a) a generic “burglary” offense, 18 U.S.C. § 924(e)(2)(B)(ii)? Il DIRECTLY