Taylor v. United States

PETITIONER: David Anthony Taylor
RESPONDENT: United States
LOCATION: U.S. District Court for the Western District of Virginia

DOCKET NO.: 14-6166
DECIDED BY: Roberts Court (2016- )
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 579 US (2016)
GRANTED: Oct 01, 2015
ARGUED: Feb 23, 2016
DECIDED: Jun 20, 2016

ADVOCATES:
Anthony A. Yang - Assistant to the Solicitor General, for the respondent
Dennis E. Jones - for the petitioner

Facts of the case

David Anthony Taylor was a member of the “Southwest Goonz,” a group of robbers based in Roanoke, Virginia, that focused on robbing drug dealers, who typically have drug proceeds in their home and are reluctant to report crime. Taylor was indicted on two counts of robbery under the Hobbs Act, which prohibits actual or attempted robbery or extortion affecting interstate or foreign commerce. At Taylor’s second trial, after his first resulted in a hung jury, the government moved to prevent Taylor from offering evidence that robbing a drug dealer who grows marijuana outside of state lines does not affect interstate commerce and therefore cannot violate the Hobbs Act. The district court granted the government’s motion, and Taylor was subsequently convicted of both counts under the Hobbs Act. Taylor moved to set aside the verdict on the grounds that the government did not present sufficient evidence that his actions affected interstate commerce. The district court denied Taylor’s motion, and the U.S. Court of Appeals for the Fourth Circuit affirmed the conviction.

Question

In a federal criminal prosecution under the Hobbs Act, is the government required to prove beyond a reasonable doubt that the robbery of a drug dealer is an inherent economic enterprise that satisfies the interstate commerce element of the offense?

Media for Taylor v. United States

Audio Transcription for Oral Argument - February 23, 2016 in Taylor v. United States

Audio Transcription for Opinion Announcement - June 20, 2016 in Taylor v. United States

John G. Roberts, Jr.:

Today's orders of the Court have been duly entered and certified and filed with the clerk.

Justice Alito has the opinion of the Court this morning in case 14-6166, Taylor versus United States.

Samuel A. Alito, Jr.:

The Hobbs Act makes it a crime to interfere with interstate commerce or to attempt to do so through robbery.

This case asks us to resolve what the government must prove to meet the interstate commerce element in Hobbs Act prosecution for robbing drug dealers.

The petitioner in this case, David Anthony Taylor, was a member of the gang that committed a series of armed home invasions that targeted drug dealers who sometimes keep drugs in large quantities and cash derived from the drug trade in their homes.

Taylor was indicted on two counts of attempted Hobbs Act robbery for his participation in two such robberies.

Taylor's first trial resulted in a hung jury.

On retrial, at the urging of the government the district court precluded Taylor from introducing evidence that the drug dealers he targeted might have been dealing in only locally grown marijuana.

The jury convicted Taylor and the United States Court of Appeals for the Fourth Circuit affirmed the conviction.

We granted certiorari to resolve a conflict in the circuits regarding what the prosecution must show in order to satisfy that the Hobbs Act's commerce element in cases involving the theft of drugs and drug proceeds from drug dealers.

We now affirm.

Our cases establish that the Hobbs Act exercises the full extent of Congress’ power under the commerce clause.

And our cases hold that this power permits Congress to regulate intrastate economic activities that substantially affect interstate commerce in the aggregate.

Applying this rule, the Court held in Gonzalez versus Raich decided in 2005 that Congress has the power to regulate the intrastate market for marijuana.

Thus, under Federal Law, a defendant may be convicted for growing or selling even a small amount of marijuana and in such a case the government is not required to prove that the defendant's conduct in itself affected interstate commerce.

It is sufficient that the aggregate impact of such commerce has that effect.

And so long as Congress may regulate intrastate drug sale it may also regulate intrastate drug theft even if an individual theft has little impact on the overall market the aggregate effect of such thefts and the theft of money derived from drug sales is sufficient.

Thus when the government seeks to prosecute a defendant for attempted Hobbs Act robbery of a drug dealer, which is what occurred in this case the government need only prove that the defendant targeted a dealer in order to obtain drugs or drug proceeds.

The evidence in this case is sufficient to establish that.

Therefore, the judgment of the Fourth Circuit is affirmed.

Justice Thomas has filed a dissenting opinion.

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