United States v. Taylor

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Supreme Court of the United States
United States v. Taylor
Term: 2021
Important Dates
Argued: December 7, 2021
Decided: June 21, 2022
Outcome
Affirmed
Vote
7-2
Majority
[Neil Gorsuch]] • Chief Justice John Roberts • Stephen Breyer • Sonia Sotomayor • Elena Kagan • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Clarence Thomas • Samuel Alito

United States v. Taylor is a case that was decided by the Supreme Court of the United States on June 21, 2022, during the court's October 2021-2022 term. The case was argued before the court on December 7, 2021.

In a 7-2 opinion, the court affirmed the United States Court of Appeals for the 4th Circuit's ruling, holding that an attempted Hobbs Act robbery does not qualify as a crime of violence under §924(c)(3)(A) because no element of the offense requires proof that the defendant used, attempted to use, or threatened to use force. Justice Neil Gorsuch wrote the majority opinion. Justices Clarence Thomas and Samuel Alito filed dissenting opinions.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In 2003, Justin Taylor was convicted of conspiracy to commit a Hobbs Act robbery and with using a firearm in furtherance of a "crime of violence." In 2016, the U.S. Court of Appeals for the 4th Circuit granted Taylor permission to file a second motion to vacate his conviction for use of a firearm in light of Johnson v. United States (2015), which narrowed the Armed Career Criminal Act (ACCA) definition of a violent felony. During the pendency of the motion, both the 4th Circuit and U.S. Supreme Court invalidated the statute defining a crime of violence. However, the district court denied Taylor's request to vacate. On appeal, the 4th Circuit vacated Taylor's conviction and remanded the case for resentencing. Click here to learn more about the case's background.
  • The issue: The case concerned the Hobbs Act and the definition of a "crime of violence."
  • The questions presented: "Whether 18 U.S.C. 924(c)(3)(A)’s definition of “crime of violence” excludes attempted Hobbs Act robbery, in violation of 18 U.S.C. 1951(a)."[2]
  • The outcome: The U.S. Supreme Court affirmed the United States Court of Appeals for the 4th Circuit's ruling.


    • The case came on a writ of certiorari to the United States Court of Appeals for the 4th Circuit.[3] To review the lower court's opinion, click here.

    Timeline

    The following timeline details key events in this case:

    Background

    In 2003, Justin Taylor arranged a sale with Martin Sylvester. Taylor would sell marijuana to Sylvester who in turn would sell the marijuana to other individuals. Taylor intended to steal Sylvester's money with a coconspirator rather than complete the planned transaction. The parties met in Richmond, Virginia to complete the transaction. Taylor's coconspirator, while armed with a semiautomatic pistol, demanded Sylvester's money. Sylvester refused, the pistol discharged, and Sylvester died from a gunshot wound.[3]

    The U.S. government charged Taylor with conspiracy to commit a Hobbs Act robbery and with using a firearm in furtherance of a "crime of violence", and Taylor pled guilty to those charges.[3] The government dismissed the remaining charges and the district court sentenced Taylor to 360 months of incarceration. Taylor appealed, but the appeal was dismissed based on a waiver in his plea agreement. In 2015, the district court denied Taylor's first motion to vacate his sentence. In 2016, the United States Court of Appeals for the 4th Circuit granted Taylor permission to file a second motion to vacate in light of Johnson v. United States (2015), which narrowed the Armed Career Criminal Act (ACCA) definition of a violent felony, and Welch v. United States (2016), which held that Johnson applied retroactively to cases on collateral review.[3]

    In his second motion to vacate his conviction for use of a firearm, Taylor claimed that the attempted Hobbs Act robbery and conspiracy to commit the Hobbs Act robbery no longer qualified as crimes of violence. While that motion was pending, the 4th Circuit issued its ruling in United States v. Simms, (2019), invalidating one of the 18 U.S.C. § 924(c)(3)(B)'s two clauses defining a crime of violence, and holding that conspiracy to commit Hobbs Act robbery does not qualify as a crime of violence under either clause. Also in 2019, the U.S. Supreme Court similarly invalidated the statute as being unconstitutionally vague in United States v. Davis (2019). In Taylor, the district court denied Taylor's motion, holding that the attempted robbery still qualified as a crime of violence under §924(c)(3)(A) and that Taylor's conviction for use of a firearm remained valid because it was predicated on attempted Hobbs Act robbery. Taylor petitioned the 4th Circuit for a certificate of appealability, which the court granted. The 4th Circuit vacated Taylor's § 924(c) conviction and remanded the case for resentencing.[3]

    Hobbs Act

    The following quotation from the United States Code contains the text of the Hobbs Act, 18 U.S.C. §1951:[4]

    “ 18 U.S. Code § 1951 - Interference with commerce by threats or violence


    (a) Whoever in any way or degree obstructs, delays, or affects commerce or the movement of any article or commodity in commerce, by robbery or extortion or attempts or conspires so to do, or commits or threatens physical violence to any person or property in furtherance of a plan or purpose to do anything in violation of this section shall be fined under this title or imprisoned not more than twenty years, or both.

    (b) As used in this section—

    (1) The term “robbery” means the unlawful taking or obtaining of personal property from the person or in the presence of another, against his will, by means of actual or threatened force, or violence, or fear of injury, immediate or future, to his person or property, or property in his custody or possession, or the person or property of a relative or member of his family or of anyone in his company at the time of the taking or obtaining.
    (2) The term “extortion” means the obtaining of property from another, with his consent, induced by wrongful use of actual or threatened force, violence, or fear, or under color of official right.
    (3) The term “commerce” means commerce within the District of Columbia, or any Territory or Possession of the United States; all commerce between any point in a State, Territory, Possession, or the District of Columbia and any point outside thereof; all commerce between points within the same State through any place outside such State; and all other commerce over which the United States has jurisdiction.

    (c) This section shall not be construed to repeal, modify or affect section 17 of Title 15, sections 52, 101–115, 151–166 of Title 29 or sections 151–188 of Title 45.[5]

    		”

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ Whether 18 U.S.C. 924(c)(3)(A)’s definition of “crime of violence” excludes attempted Hobbs Act robbery, in violation of 18 U.S.C. 1951(a).[5] ”

    Oral argument

    The U.S. Supreme Court heard oral argument on December 7, 2021.

    Audio

    Audio of oral argument:[6]



    Transcript

    Transcript of oral argument:[7]

    Outcome

    In a 7-2 opinion, the court affirmed the United States Court of Appeals for the 4th Circuit's ruling, holding that an attempted Hobbs Act robbery does not qualify as a crime of violence under §924(c)(3)(A) because no element of the offense requires proof that the defendant used, attempted to use, or threatened to use force. Justice Neil Gorsuch wrote the majority opinion. Justices Clarence Thomas and Samuel Alito filed dissenting opinions.[1]

    Opinion

    In the court's majority opinion, Justice Neil Gorsuch wrote:[1]

    “ Does attempted Hobbs Act robbery qualify as a “crime of violence” under 18 U. S. C. § 924(c)(3)(A)? The answer mat- ters because a person convicted of attempted Hobbs Act robbery alone normally faces up to 20 years in prison. But if that offense qualifies as a “crime of violence” under § 924(c)(3)(A), the same individual may face a second felony conviction and years or decades of further imprisonment.


    ... The government quickly abandons the legal theory it advanced in the courts of appeals—and neither of the two new options it auditions before us begins to fill the void. In § 924(c)(3)(A), Congress did not condition long prison terms on an abstract judicial inquiry into whether and to what degree this or that crime poses a risk to community peace and safety. Nor did it mandate an empirical inquiry into how crimes are usually committed, let alone impose a bur- den on the defendant to present proof about the government’s own prosecutorial habits.

    Congress tasked the courts with a much more straight- forward job: Look at the elements of the underlying crime and ask whether they require the government to prove the use, attempted use, or threatened use of force. Following that direction in this case, the Fourth Circuit correctly recognized that, to convict a defendant of attempted Hobbs Act robbery, the government does not have to prove any of those things. Accordingly, Mr. Taylor may face up to 20 years in prison for violating the Hobbs Act. But he may not be lawfully convicted and sentenced under § 924(c) to still another decade in federal prison. The judgment of the Court of Appeals is affirmed.[5]

    		”
    —Justice Neil Gorsuch


    Dissenting opinion

    Justice Thomas

    Justice Clarence Thomas filed a dissenting opinion.

    In his dissent, Justice Thomas wrote:[1]

    “ This holding exemplifies just how this Court’s “categorical approach” has led the Federal Judiciary on a “journey Through the Looking Glass,” during which we have found many “strange things.” L. Carroll, Alice in Wonderland and Through the Looking Glass 227 (J. Messner ed. 1982). Ra- ther than continue this 30-year excursion into the absurd, I would hold Taylor accountable for what he actually did and uphold his conviction. Accordingly, I respectfully dissent.[5] ”
    —Justice Clarence Thomas

    Justice Alito

    Justice Samuel Alito filed a dissenting opinion.

    In his dissent, Justice Alito wrote:[1]

    “ The Court holds that this violent (and, indeed, deadly) offense did not constitute a “crime of violence” under the technical definition of that term in §924(c)(3)(A). I agree with JUSTICE THOMAS that our cases involving §924(c)(3)(A) have veered off into fantasy land. But if the Court is going to disregard the real world and base its decisions in this area on a strict reading of the text, the “offense” for which Taylor was convicted—attempted Hobbs Act robbery— meets the definition in §924(c)(3)(A). That definition provides that an “offense” qualifies as a “ ‘crime of violence’ ” if it is a felony and “has as an element the use, attempted use, or threatened use of physical force against the person . . . of another.” (Emphasis added.)


    ... I believe that the Court’s approach and ultimate holding in this case are misguided. I would hold that Taylor committed a “crime of violence” within the meaning of §924(c)(3)(A) and reverse the judgment of the Fourth Circuit below. But there is a silver lining in the majority opinion. Because the Court assumes—and does not hold—that alternative elements do not qualify as independent elements of a crime for purposes of applying §924(c)(3)(A), the Government remains free to advance the correct interpretation of that provision in a future case. For my purposes, however, the text of the statute is clear enough to support reversal here and now. As a result, I respectfully dissent.[5]

    		”
    —Justice Samuel Alito

    Text of the opinion

    Read the full opinion here.

    Additional reading

    The following list of previously decided Supreme Court cases relate to legal precedents at issue in the case.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[8]

    The court agreed to hear 68 cases during its 2021-2022 term.[9] Four cases were dismissed and one case was removed from the argument calendar.[10]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 1.4 U.S. Supreme Court, United States v. Taylor, decided June 21, 2022
    2. ↑ 2.0 2.1 U.S. Supreme Court, "United States v. Taylor: PETITION FOR A WRIT OF CERTIORARI," filed April 14, 2021
    3. ↑ 3.0 3.1 3.2 3.3 3.4 United States Court of Appeals for the 4th Circuit, United States v. Taylor, decided October 14, 2020
    4. ↑ Cornell Law School Legal Information Institute, "18 U.S. Code § 1951 - Interference with commerce by threats or violence," accessed July 6, 2021
    5. ↑ 5.0 5.1 5.2 5.3 5.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued December 7, 2021
    7. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued December 7, 2021
    8. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    9. ↑ Consolidated cases are counted as one case for purposes of this number.
    10. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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