Opinion of the Court
basic robbery], armed robbery, and attempted robbery… the same for purposes of analyzing the ACCA’s elements clause”).
Where, as here, the applicability of a federal criminal statute requires a state conviction, we have repeatedly declined to construe the statute in a way that would render it inapplicable in many States. See, e. g., United States v. Castleman, 572 U. S. 157, 167 (2014) (reading “physical force” to include common-law force, in part because a different reading would render 18 U. S. C. §922(g)(9) “ineffectual in at least 10 States”); Voisine v. United States, 579 U. S. ___, ___ (2016) (slip op., at 9) (declining to interpret §912(a)(33)(A) in a way that would “risk rendering §922(g)(9) broadly inoperative” in 34 States and the District of Columbia). That approach is appropriate here as well.
B
Our understanding of “physical force” comports with Johnson v. United States, 559 U. S. 133 (2010). There, the Court held that “ ‘actua[l] and intentiona[l] touching’ ”–the level of force necessary to commit common-law misdemeanor battery–did not require the “degree of force” necessary to qualify as a “violent felony” under ACCA’s elements clause. Id., at 138, 140. To reach this conclusion, the Court parsed the meaning of the phrase “physical force.” First, it explained that the modifier “physical” “plainly refers to force exerted by and through concrete bodies–distinguishing physical force, from, for example, intellectual force or emotional force.” Id., at 138. The Court then considered “whether the term ‘force’ in [the elements clause] has the specialized meaning that it bore in the common-law definition of battery.” Id., at 139. After reviewing the context of the statute, the Court rejected the Government’s suggestion that “force” encompassed even the “slightest offensive touching.” Ibid.
