United States v. Alfredo Avalos-Sanchez, 975 F.3d 436

In June 2017 Avalos‑Sanchez acted as a lookout for a crew that planned to rob what they believed was a drug dealer’s house to steal large quantities of drugs and drug proceeds.
On June 6 the crew invaded the wrong residence; they nonetheless held four occupants at gunpoint and stole $700 and two cell phones.
Avalos‑Sanchez was indicted under the Hobbs Act, pleaded guilty to Count Three (robbery affecting commerce), and admitted at re‑arraignment that he joined the plot and intended to steal hundreds of pounds of marijuana or over five kilograms of cocaine.
The district court sentenced him to 87 months’ imprisonment.
On appeal Avalos‑Sanchez argued (1) the factual basis for his guilty plea was insufficient to establish the Hobbs Act’s commerce element, and (2) his plea was not knowing/voluntary because he did not know the factual basis was insufficient.
The Fifth Circuit reviewed both claims for plain error and affirmed, holding the record (and Taylor v. United States) show that intent to steal drugs satisfies the Hobbs Act commerce element and the plea colloquy established a knowing, voluntary plea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of factual basis for Hobbs Act (commerce element)	Government: Avalos‑Sanchez admitted intent to steal drugs/drug proceeds; under Taylor intent to steal drugs is enough to satisfy commerce element.	Avalos‑Sanchez: admissions insufficient because actual victims were not drug dealers and no drugs/drug proceeds were taken; plea lacked factual basis.	Affirmed — admissions at re‑arraignment establish intent to steal controlled substances; Taylor controls; factual basis sufficient.
Voluntariness/knowing plea	Government: plea colloquy explained elements, rights, and consequences; plea was knowing and voluntary.	Avalos‑Sanchez: plea involuntary because he was unaware the factual basis was insufficient on the commerce element.	Affirmed — because factual basis was sufficient and the colloquy shows he knowingly and voluntarily pleaded guilty.

Taylor v. United States, 136 S. Ct. 2074 (2016) (intent to steal drugs or drug proceeds from drug dealers satisfies Hobbs Act commerce element)
United States v. Broussard, 669 F.3d 537 (5th Cir. 2012) (factual‑basis specificity for guilty pleas)
United States v. Marek, 238 F.3d 310 (5th Cir. 2001) (en banc) (plain‑error review when a defendant fails to object below)
United States v. Trejo, 610 F.3d 308 (5th Cir. 2010) (discussing difficulty of meeting plain‑error standard)
Vonn v. United States, 535 U.S. 55 (2002) (guilty plea must be voluntary and knowing)
Brady v. United States, 397 U.S. 742 (1970) (same)
Boykin v. Alabama, 395 U.S. 238 (1969) (trial court must ensure waiver of constitutional rights is voluntary)