United States v. Taylor
In brief
The Supreme Court upheld the Fourth Circuit’s ruling: attempted Hobbs Act robbery does not count as a “crime of violence” under §924(c)(3)(A).
- Where it stands
- Decided
Decided 7-2 · June 21, 2022 · Opinion by Justice Gorsuch
- What it’s about
- In this case, the Supreme Court decided whether an attempted Hobbs Act robbery qualifies as a 'crime of violence' under federal law.
- Who it affects
- An attempted Hobbs Act robbery cannot count as the required “crime of violence” for a firearm charge under §924(c)(3)(A). Similar cases must be analyzed under that rule.
Summary: written with AI from the case record.
What it's about
The Court ruled that it does not, because the crime can be committed without the actual, attempted, or threatened use of physical force.
Federal law can classify an offense by its required legal parts, rather than only by the facts of one attempted robbery.
Question presented
Does the definition of “crime of violence” in 18 U.S.C. § 924(c)(3)(A) exclude attempted Hobbs Act robbery, which may be completed through an attempted threat alone?
What the Court decided
Holding
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. 979 F. 3d 203, affirmed.
- Result
- Affirmed
The vote
From the opinions
“Rather than continue this 30-year excursion into the absurd, I would hold Taylor accountable for what he actually did and uphold his conviction.”
What's next
Lower courts should apply this rule when deciding similar §924(c)(3)(A) firearm cases. The Supreme Court’s review of this case is complete.
Documents
Docket activity
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AI analysis generated: Case Briefing
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
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More questions
- What did United States v. Taylor decide?
- The Court decided that attempted Hobbs Act robbery is not a “crime of violence” under §924(c)(3)(A).
- What prevented attempted Hobbs Act robbery from qualifying?
- The offense does not require proof that the defendant used, tried to use, or threatened to use physical force.
- How does Taylor affect federal firearm charges?
- An attempted Hobbs Act robbery cannot count as the qualifying offense for a firearm charge under §924(c)(3)(A).
- What happens next after the decision?
- Lower courts should apply the ruling in similar §924(c)(3)(A) cases. The Supreme Court’s review of Taylor is complete.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.