In the case of Stokeling v. United States, 2018, Denard Stokeling was convicted for a robbery in Florida and later charged under the Armed Career Criminal Act (ACCA) after being found in possession of a firearm. The ACCA imposes a mandatory minimum sentence on individuals who have three prior convictions for violent felonies. However, Stokeling argued that his previous conviction did not qualify as it didn't involve enough physical force to meet the definition of "violent felony" under ACCA's terms. The Supreme Court disagreed with this argument by ruling 5-4 that even minimal force required to overcome victim resistance can constitute as violent felony under ACCA guidelines. Therefore, they upheld that his earlier robbery conviction could be used to enhance his current sentencing.

In the dissenting opinion for Stokeling v. United States, Justice Sonia Sotomayor argued that the majority's interpretation of "physical force" was too broad and inconsistent with precedent. She contended that a robbery offense should only qualify as a violent felony under the Armed Career Criminal Act (ACCA) if it involves substantial physical force or violence. According to her, this means more than mere touching but rather strong physical force capable of causing pain or injury. In contrast to the majority’s view, she believed Florida law does not require such level of force in robbery offenses; therefore, they should not automatically be considered violent felonies under ACCA. She also expressed concern about potential implications on federalism and separation-of-powers principles by allowing federal courts to expand state-law crimes into generic offenses.