Taylor v. United States, 136 S. Ct. 2074

Background

In 2009 petitioner Anthony Taylor participated in two home-invasion robberies in Roanoke, Virginia that targeted suspected marijuana dealers; the robberies sought drugs and drug proceeds.
Taylor was indicted and convicted on two Hobbs Act robbery counts (18 U.S.C. § 1951(a)) and one firearms count; convictions were affirmed by the Fourth Circuit and certiorari was granted to resolve circuit splits.
The Hobbs Act criminalizes robbery that "affects" "commerce over which the United States has jurisdiction" and defines "commerce" broadly in § 1951(b)(3).
The central legal question: what must the Government prove to satisfy the Hobbs Act's commerce element when the robbery targets a drug dealer's drugs or drug proceeds?
The Court majority relied on Gonzales v. Raich and the aggregation/substantial-effects doctrine to hold that robbing (or attempting to rob) a drug dealer of drugs or drug proceeds satisfies the Hobbs Act commerce element as a matter of law.
Justice Thomas dissented, arguing the Hobbs Act requires proof that the particular robbery itself affected interstate commerce and that the majority's reading undermines constitutional limits and criminal-law protections.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether proving a robbery targeted a marijuana dealer is sufficient to satisfy the Hobbs Act commerce element	Government: If defendant knowingly stole or attempted to steal drugs or drug proceeds, that proof establishes the robbery affected "commerce over which the United States has jurisdiction" under Raich	Taylor: Government must prove more — e.g., that the specific drugs traveled interstate or the dealer operated an interstate business; the Hobbs Act requires proof the robbery itself affected commerce	Held: Proof that the defendant knowingly targeted a drug dealer for drugs or drug proceeds is sufficient as a matter of law to satisfy the Hobbs Act commerce element (affirming Fourth Circuit)
Scope of Raich for Hobbs Act purposes	Government: Raich establishes Congress may regulate intrastate marijuana market; therefore intrastate drug sale is commerce under §1951(b)(3)	Taylor: Raich involved CSA (no jurisdictional element) and used a rational-basis/aggregation inference — it does not eliminate the Hobbs Act's separate commerce-element proof requirement	Held: Raich controls; because Congress can regulate the intrastate marijuana market, robbery of a drug dealer falls within "commerce over which the United States has jurisdiction" without needing proof of interstate travel
Whether aggregation/substantial-effects approach can be applied in criminal prosecutions under Hobbs Act	Government: When the target is a drug dealer, the activity falls within a class that in the aggregate affects interstate commerce, so individual proof of effect is unnecessary	Taylor: Applying aggregation here removes required proof beyond a reasonable doubt that the robbery itself affected commerce and expands federal power improperly	Held: Majority applies the aggregation principle to conclude targeted drug-dealer robberies meet the Hobbs Act commerce element; dissent disagrees on constitutional and doctrinal grounds
Limitation of the decision's scope	Government: N/A (seeks broad application to drug-dealer-targeted robberies)	Taylor/Dissent: Hobbs Act should be limited to robberies that themselves affect interstate commerce (channels/instrumentalities), not all intrastate robberies	Held: Majority limits its holding to cases where defendant targeted drug dealers to steal drugs or drug proceeds; leaves other Hobbs Act contexts open

Key Cases Cited

Gonzales v. Raich, 545 U.S. 1 (2005) (Congress may regulate purely intrastate marijuana activity as part of the national market)
Wickard v. Filburn, 317 U.S. 111 (1942) (aggregation principle: local economic activity may be regulated if, in the aggregate, it substantially affects interstate commerce)
United States v. Lopez, 514 U.S. 549 (1995) (three categories of Commerce Clause regulation and limits on federal power)
United States v. Morrison, 529 U.S. 598 (2000) (recognizes limits and that regulation under the commerce power must concern economic activity)
Perez v. United States, 402 U.S. 146 (1971) (applied substantial-effects reasoning to criminal statute regulating loansharking)
Stirone v. United States, 361 U.S. 212 (1960) (Hobbs Act's language is broad and congressional reach is expansive)
United States v. Culbert, 435 U.S. 371 (1978) (Hobbs Act's words do not lend themselves to restrictive interpretation)
United States v. Enmons, 410 U.S. 396 (1973) (construed Hobbs Act narrowly as to legitimate union objectives; demonstrates federalism/lenity considerations)
McCulloch v. Maryland, 17 U.S. 316 (1819) (necessary and proper principle limiting federal power)
In re Winship, 397 U.S. 358 (1970) (requires proof beyond a reasonable doubt of every element of a crime)