Williams: Florida Battery does not Qualify for Career Offender

In U.S. v. Williams, No. 08-10184 (June 22, 2010), on remand from the United States Supreme Court in light of Johnson v. U.S., 130 S.Ct. 1265 (2010), the Court held that a prior Florida State conviction for battery on a law enforcement officer did not qualify as a crime of violence for career offender sentencing purposes. The Court noted that battery did not necessarily involve the requisite "physical force." Nor did the factual record so indicate. The Court therefore vacated the sentence and remanded for resentencing.