Taylor v. United States

136 S.Ct. 2074 (2016)

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Nature of the Case

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Facts

An outlaw gang called the “Southwest Goonz” committed a series of home invasion robberies targeting drug dealers in the area of Roanoke, Virginia. D and others targeted the home of Josh Whorley because they heard that Whorley dealt “exotic and high grade” marijuana. D and the others broke into the home, searched it, and assaulted Whorley and his girlfriend. They left with only jewelry, $40, two cell phones, and a marijuana cigarette. On a second attempt, D and others broke into Lynch’s home, held his wife and young children at gunpoint, assaulted his wife, and demanded to know the location of his drugs and money. The robbers made off with only a cell phone. D was indicted under the Hobbs Act on two counts of affecting commerce or attempting to do so through robbery. During a second trial, D twice moved for a judgment of acquittal on the ground that the prosecution had failed to meet its burden on the commerce element. The court denied those motions. It held that the proof that D attempted to rob drug dealers was sufficient as a matter of law to satisfy that element. D was found guilty and appealed. The appeals court affirmed: “Because drug dealing in the aggregate necessarily affects interstate commerce,” the court reasoned, “the government was simply required to prove that Dr depleted or attempted to deplete the assets of such an operation.” The Supreme Court granted certiorari.