United States v. Taylor

In United States v. Taylor, decided June 21, 2022, the U.S. Supreme Court addressed whether attempted Hobbs Act robbery constitutes a "crime of violence" under the Armed Career Criminal Act (ACCA). Justin Taylor had received a 15-year mandatory minimum sentence as an armed career criminal based in part on a prior conviction for aiding and abetting attempted Hobbs Act robbery. The Court, in a 7-2 decision written by Justice Gorsuch, held that this predicate offense does not satisfy ACCA's elements clause because an attempt does not necessarily require the use, attempted use, or threatened use of physical force against another person. The Court emphasized that a conviction for attempt can rest on a substantial step that involves no violent force, thereby rejecting the government's argument and overruling the Fourth Circuit. The ruling limits the reach of mandatory minimum sentences under ACCA.

The Supreme Court reversed the Fourth Circuit, holding 7-2 that attempted Hobbs Act robbery does not categorically require violent force and therefore cannot serve as a predicate ACCA violent felony. Justin Taylor's enhanced sentence was vacated, and the case was remanded for resentencing.

Whether aiding and abetting attempted Hobbs Act robbery qualifies as a "crime of violence" under the elements clause of the Armed Career Criminal Act (18 U.S.C. § 924(c)), which requires an offense to have as an element the use, attempted use, or threatened use of physical force against the person or property of another.

The decision reinforces the categorical approach to sentencing enhancements, limits the application of mandatory minimum sentences under ACCA, and impacts federal prosecutors' ability to use inchoate robbery offenses to trigger severe penalties. It also highlights the Court's textualist methodology in criminal law interpretation.