| No search history |
Your feedback is extremely important to us and greatly appreciated.
Tell us what went wrong

14-6166 TAYLOR V. UNITED STATES DECISION BELOW: 754 F.3d 217 CERT. GRANTED 10/1/2015 QUESTION PRESENTED: Whether, in a federal criminal prosecution under the Hobbs Act, 18 U.S.C. §1951, the Government is relieved of proving beyond a reasonable doubt the interstate commerce element by relying exclusively on evidence that the robbery or attempted robbery of a drug dealer is an inherent economic enterprise that satisfies, as a matter of law, the interstate commerce element of the offense. LOWER COURT CASE NUMBER: 13-4316
In the case of Taylor v. United States in 2015, David Anthony Taylor was convicted under the Hobbs Act for robbing two drug dealers in Virginia. The Hobbs Act criminalizes robberies affecting interstate commerce. On appeal, Taylor argued that the government failed to prove his robberies affected interstate commerce as required by law. However, both lower courts ruled against him stating that drug dealing inherently affects interstate commerce and thus any robbery of a drug dealer does too. The Supreme Court affirmed these decisions with a unanimous vote (8-0). Justice Samuel Alito wrote for the court explaining that because drugs are typically part of an out-of-state supply chain, their theft would indeed affect interstate commerce regardless if it's proven or not in each individual case.
In the dissenting opinion for Taylor v. United States, Justice Clarence Thomas argued that the majority's interpretation of the Hobbs Act was too broad and not in line with Congress' original intent. He contended that to prove a violation of the Act, it must be shown that there is an actual effect on interstate commerce, not just a potential or theoretical one as suggested by the majority ruling. Furthermore, he believed this case should have been dismissed because no evidence was presented showing any impact on interstate commerce from two local robberies in Virginia. By expanding federal jurisdiction into purely local crimes without clear proof of an effect on interstate commerce, Thomas warned against undermining state sovereignty and blurring constitutional boundaries between federal and state criminal law enforcement responsibilities.