Whitfield Leland III was convicted of Hobbs Act robbery, brandishing a firearm during a crime of violence, and possession of a firearm as a convicted felon following a 2024 robbery at a Dollar General in Tallahassee, Florida. During the incident, Leland brandished a handgun, demanded cash and access to a safe, and attempted to flee by disguising himself in a store uniform before being apprehended. At sentencing, the district court applied the Armed Career Criminal Act (ACCA) enhancement, which triggers a 15-year mandatory minimum sentence for felons with three prior convictions for violent felonies or serious drug offenses. Leland's criminal history included two prior battery convictions and a 2011 conviction for aggravated assault with a deadly weapon. While he did not waive his right to challenge the ACCA application, he argued that the 2011 aggravated assault conviction did not qualify as a violent felony predicate offense. The district court imposed a 264-month sentence, combining the mandatory minimums with the advisory guideline range.
The Eleventh Circuit reviewed the classification of the 2011 Florida conviction de novo. Under the ACCA, a prior conviction qualifies as a violent felony if it has as an element the use, attempted use, or threatened use of physical force against the person of another. Courts apply a categorical approach, examining whether the state statute necessarily involves that degree of force. The court relied on its prior decision in Somers v. United States, which held that Florida assault statutes require a mens rea of at least knowing conduct and cannot be committed recklessly. Because the ACCA excludes reckless conduct from the definition of a violent felony, the court concluded that Florida aggravated assault categorically satisfies the federal elements clause. Leland argued that the Supreme Court's decision in Brown v. United States, which required a backward-looking examination of drug definitions, undermined the Somers analysis. The court rejected this, noting that Brown addressed legislative amendments to drug schedules, whereas the Florida assault statute's language has remained unchanged since 2011. The court clarified that Brown did not address violent felonies or judicial statutory interpretation of state laws. Consequently, the Somers precedent remained binding, and the district court did not err in applying the enhancement.
The 264-month sentence remains in effect. The decision reinforces the binding nature of the Eleventh Circuit's Somers precedent regarding Florida assault statutes and clarifies that Brown v. United States does not alter the analysis for violent felony predicates where the state statute has not been amended. No remand instructions were issued.