As to the conviction, the Court concluded that the district court did not abuse its discretion in supplementing its jury instruction on possession in response to a jury question. The Court reasoned that the court's original possession instruction was correct, the court's answer referred back to the original instruction, it did not misstate the law, and it appropriately resolved any potential confusion in light of the government's theory of the case. The Court further noted that the defendant's proposed response was not a correct statement of the law, and the court's answer was more beneficial to the defendant. The Court rejected the defendant's argument that the district court was required to say more given its substantial discretion.
As for the ACCA sentence, the Court held that attempted Florida robbery satisfied the elements clause, relying on its prior precedents holding that substantive robbery satisfied the elements clause. Notably, and as the Court itself observed, the defendant did not argue that the attempt component distinguished his offense from substantive robbery, and so the Court did not address any of the arguments for why attempted robbery might be different than substantive robbery. The Court also reiterated its prior precedent that resisting with violence satisfied the elements clause, and that prior convictions need not be charged in the indictment or proved beyond a reasonable doubt.
