In the case of Curtis Darnell Johnson v. United States, 2009, the U.S. Supreme Court was tasked with determining whether a prior conviction for battery under Florida law constituted a "violent felony" under the Armed Career Criminal Act (ACCA). The ACCA imposes a mandatory minimum sentence of 15 years for individuals convicted of being felons in possession of firearms who have three or more previous convictions for violent felonies or serious drug offenses. Johnson had been previously convicted on charges including simple battery in Florida and was subsequently charged with illegal possession of ammunition by a convicted felon. The District Court ruled that his earlier battery conviction qualified as a violent felony and sentenced him to fifteen years imprisonment under ACCA guidelines. However, upon appeal to the Supreme Court, it was held that not all physical contact can be classified as 'violent force' - which is necessary to categorize an offense as 'violent felony'. In this context, they found that Florida's definition of ‘battery’ – essentially any intentional physical contact no matter how slight – did not meet this standard because it could include even minor instances such as touching someone against their will without causing injury. Therefore, Johnson’s previous conviction did not qualify as a “violent felony” under federal law.

In the dissenting opinion for Curtis Darnell Johnson v. United States, Justice Clarence Thomas argued that the majority's interpretation of "physical force" was too narrow and inconsistent with ordinary usage. He contended that it is not necessary for physical force to carry violent connotations or cause pain or injury in order to qualify as a felony under Florida law. The justice also pointed out inconsistencies between this ruling and previous ones regarding similar cases, stating that the court had previously upheld convictions based on less severe forms of physical contact than battery. Furthermore, he criticized the majority’s reliance on dictionary definitions instead of legal precedent when interpreting statutory language.