United States v. Louis Pasquazzi

CourtCourt of Appeals for the Eleventh Circuit
DecidedMay 8, 2025
Docket23-12994
StatusUnpublished

This text of United States v. Louis Pasquazzi (United States v. Louis Pasquazzi) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Louis Pasquazzi, (11th Cir. 2025).

Opinion

USCA11 Case: 23-12994 Document: 43-1 Date Filed: 05/08/2025 Page: 1 of 17

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 23-12994 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus LOUIS MICHAEL PASQUAZZI,

Defendant-Appellant.

Appeal from the United States District Court for the Middle District of Florida D.C. Docket No. 2:23-cr-00010-SPC-NPM-1 ____________________ USCA11 Case: 23-12994 Document: 43-1 Date Filed: 05/08/2025 Page: 2 of 17

2 Opinion of the Court 23-12994

Before JORDAN, LUCK, and ANDERSON, Circuit Judges. PER CURIAM: Louis Pasquazzi appeals his conviction and 216-month sen- tence for possession of a firearm by a convicted felon and posses- sion with intent to distribute a controlled substance. On appeal, Pasquazzi challenges his designation as an armed career criminal. He first argues that his prior Florida conviction for aggravated as- sault was improperly categorized as a violent felony under the Armed Career Criminal Act (“ACCA”). Second, he argues that his prior Florida aggravated battery conviction was improperly cate- gorized as a violent felony under the ACCA because Florida aggra- vated battery can rest on simple battery. Third, he argues that his prior Florida cocaine conviction was improperly categorized as a serious drug offense under the ACCA. Lastly, Pasquazzi argues that his conviction for possession of a firearm by a convicted felon, in violation of 18 U.S.C. § 922(g)(1), violates the Commerce Clause facially and as applied to him. I. Aggravated Assault We review de novo whether a prior conviction qualifies as a violent felony under the ACCA. United States v. Vereen, 920 F.3d 1300, 1312 (11th Cir. 2019). To qualify as a violent felony under the ACCA’s elements clause, a conviction must have “as an element the use, attempted use, or threatened use of physical force against the person of an- other.” 18 U.S.C. § 924(e)(2)(B). We employ the categorical USCA11 Case: 23-12994 Document: 43-1 Date Filed: 05/08/2025 Page: 3 of 17

23-12994 Opinion of the Court 3

approach to determine whether a conviction necessarily requires the use or threatened use of physical force, looking only at the ele- ments of a defendant’s prior offenses and not to the facts underly- ing those convictions. United States v. Jones, 906 F.3d 1325, 1327-28 (11th Cir. 2018). An offense is a violent felony under the ACCA “if even the least culpable conduct criminalized by the statute would fall within the ACCA definition.” Id. at 1328 (quotation marks omitted). When determining what the elements of a state offense are, a reviewing court must look to the state’s case law defining those elements. United States v. Rosales-Bruno, 676 F.3d 1017, 1021 (11th Cir. 2012). In Florida, an aggravated assault is “an assault: (a) [w]ith a deadly weapon without intent to kill; or (b) [w]ith an intent to commit a felony.” Fla. Stat. Ann. § 784.021. An assault is defined as “an intentional, unlawful threat by word or act to do violence to the person of another, coupled with an apparent ability to do so, and doing some act which creates a well-founded fear in such other person that such violence is imminent.” Id. § 784.011. In McNeill v. United States, in the context of the ACCA, the Supreme Court explained that, because the ACCA requires the court to determine whether a previous conviction was a “serious drug offense,” it must look backward and “consult the law that ap- plied at the time of that conviction.” 563 U.S. 816, 820 (2011). It held that, even though Congress used present tense language in the ACCA, it was not persuaded that Congress intended to “look any- where other than the law under which the defendants were USCA11 Case: 23-12994 Document: 43-1 Date Filed: 05/08/2025 Page: 4 of 17

4 Opinion of the Court 23-12994

actually convicted to determine the elements of their offenses.” Id. at 821-22. The Court also expressed that it would be “absurd” to consult current state law to define a previous offense. Id. at 822; but see Johnson v. United States, 576 U.S. 591, 604-05 (2015) (“Con- gress intended the sentencing court to look only to the fact that the defendant had been convicted of crimes falling within certain cate- gories, and not to the facts underlying the prior convictions.”) In Turner v. Warden Coleman FCI (Medium), we held that Flor- ida aggravated assault categorically qualifies as a violent felony un- der the ACCA’s elements clause. 709 F.3d 1328, 1338 (11th Cir. 2013). Specifically, we held that “by its definitional terms,” an as- sault requires the threatened use of violence against another. Id. In United States v. Golden, we held that Turner foreclosed the appellant’s argument that a Florida conviction for aggravated as- sault did not constitute a “crime of violence” under U.S.S.G. § 4B1.2(a)(1) of the Sentencing Guidelines. 854 F.3d 1256, 1256-57 (11th Cir. 2017). We noted that “some members of our court have questioned the continuing validity of Turner,” but continued, “even if Turner is flawed, that does not give us, as a later panel, the au- thority to disregard it.” Id. at 1257. In Borden v. United States, a plurality of the Supreme Court concluded that a criminal offense that can be committed with a mens rea of recklessness does not qualify as a “violent felony” under the ACCA’s elements clause. 593 U.S. 420, 441-42 (2021) (plurality opinion). Ultimately, the Court reversed and remanded Borden’s ACCA-enhanced sentence, which had been based in part on a prior USCA11 Case: 23-12994 Document: 43-1 Date Filed: 05/08/2025 Page: 5 of 17

23-12994 Opinion of the Court 5

Tennessee conviction for reckless aggravated assault. Id. at 444 (plurality opinion). In Somers, we originally affirmed the denial of a 28 U.S.C. § 2255 motion, holding that the movant’s Florida aggravated as- sault conviction under § 784.021 qualified as a violent felony under the ACCA’s elements clause under Turner and Golden. Somers v. United States, 799 F. App’x 691, 692-93 (11th Cir. 2020) (“Somers I”) (unpublished). We then held the mandate pending the Supreme Court’s decision in Borden, and, after Borden was decided, granted rehearing, vacated the former opinion, substituted a new opinion in its place, and certified to the Florida Supreme Court two ques- tions regarding Florida’s assault statute: 1. Does the first element of assault as defined in Fla. Stat. § 784.011(1) – “an intentional, unlawful threat by word or act to do violence to the person of another” – require specific intent? 2. If not, what is the mens rea required to prove that element of the statute? Somers v. United States, 15 F.4th 1049

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