Brief of the National Association of Criminal Defense Lawyers as Amicus Curiae in Support of Petitioner (on petition for a writ of certiorari).
Argument: The circuit court split thwarts the Court's rationales in adopting the categorical approach. The Court should grant review to clarify whether Congress intended the ACCA to target purse snatching and other non-violent robberies. The Court should grant review to resolve inconsistencies in applying the categorical approach. The Court should grant review to clarify the "realistic probability" analysis.