Jesus Rosales-Bruno pleaded guilty to illegal reentry after deportation and received an 87-month sentence, including a sixteen-level enhancement based on the conclusion that his prior Florida false-imprisonment conviction was a crime of violence. The Eleventh Circuit vacated the sentence and remanded for resentencing. Applying the modified categorical approach, the court held that Florida’s false-imprisonment statute covers conduct that may be accomplished without the violent physical force required by the Guidelines. The government therefore had to prove from reliable conviction records that Rosales-Bruno’s particular plea necessarily rested on qualifying force. The information and judgment merely tracked statutory language and did not establish that fact. The court also refused to rely on the arrest affidavit because it was prepared to establish probable cause rather than record an admitted factual basis, and Rosales-Bruno had specifically disputed the relevant paragraph of the presentence report. Because the government failed to show that the prior conviction necessarily involved a crime of violence, the enhancement was erroneous. The court expressed no view on the proper sentence and directed the district court to resentence under the § 3553(a) factors.