Background
Christopher Pinkston was convicted of federal bank robbery and Florida aggravated assault. He later committed additional bank robberies and pleaded guilty to new charges. A probation officer determined Pinkston was a career offender under the Sentencing Guidelines because his prior convictions for bank robbery and aggravated assault were crimes of violence. The district court enhanced his sentence, setting a guideline range of one hundred fifty-one to one hundred eighty-eight months, and sentenced him to one hundred sixty months.
The court’s reasoning
The court applied the categorical approach to determine if Pinkston’s prior convictions were crimes of violence. It found that federal bank robbery requires knowing intimidation, which satisfies the elements clause, and is also listed as an enumerated crime of violence. Regarding Florida aggravated assault, the court relied on a definitive ruling from the Supreme Court of Florida clarifying that the statute requires at least knowing conduct. The court rejected the argument that it should look only at the law as interpreted by intermediate appellate courts at the time of conviction, holding that state supreme court interpretations define what the statute always meant.
What it means going forward
The ruling reinforces the Eleventh Circuit’s precedent that federal bank robbery and Florida aggravated assault are crimes of violence for sentencing enhancements. It clarifies that federal courts must apply the most recent authoritative interpretation of state law when evaluating prior convictions, even if that interpretation postdates the defendant’s original offense.