United States v. David Anthony Taylor
2014 U.S. App. LEXIS 10559
4th Cir.2014Background
- Taylor appeals his Hobbs Act robbery convictions and a 924(c) conviction.
- He argues the government failed to prove the robbies affected interstate commerce and seeks to introduce evidence that Virginia-grown marijuana did not affect interstate commerce.
- The government invokes aggregation, arguing drug-dealing enterprises affect interstate commerce in the aggregate.
- Two robberies are analyzed: Whorley (August 27, 2009) targeting marijuana and proceeds; Lynch (October 21, 2009) targeting marijuana and proceeds.
- The district court precluded Virginia-only evidence on interstate commerce; the jury found depleting assets or targeting enterprise suffices.
- The court affirms; Hobbs Act reach is broad and supports aggregation; 924(c) conviction upheld.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does aggregation prove Hobbs Act jurisdiction? | Taylor contends no jurisdiction without individual impact. | Taylor argues only specific acts impact commerce. | Aggregation sufficient; jurisdiction established. |
| Must each robbery show direct impact on interstate commerce? | Taylor argues no, evidence lacking should defeat jurisdiction. | States minimal/aggregate impact suffices. | No per-incident proof required; aggregate impact enough. |
| Was the district court's pretrial ruling about Virginia-grown marijuana correct? | Taylor sought to show no interstate commerce impact for Virginia-grown drugs. | Drug dealing inherently affects interstate commerce; evidence irrelevant. | Court did not abuse discretion; ruling correct. |
| Does the targeting/depletion-of-assets theory support Hobbs Act jurisdiction here? | Requests reversal absent proof of impact on commerce. | Either depletion of assets or targeted enterprise suffices. | Support established under both theories; jurisdiction supported. |
| Does the Hobbs Act reach justify upholding the 924(c) conviction? | If Hobbs Act predicate is infirm, 924(c) fails. | Predicate is valid, so 924(c) stands. | Hobbs Act convictions valid, so 924(c) conviction affirmed. |
Key Cases Cited
- United States v. Williams, 342 F.3d 350 (4th Cir. 2003) (aggregation allowed; drug dealing affects interstate commerce)
- United States v. Tillery, 702 F.3d 170 (4th Cir. 2012) (aggregation principle in Hobbs Act context)
- Raich v. Gonzalez, 545 U.S. 1 (2005) (aggregate impact on interstate commerce authority)
- Wickard v. Filburn, 317 U.S. 111 (1942) (aggregate effects on price and market conditions)
- United States v. Buffey, 899 F.2d 1402 (4th Cir. 1990) (de minimis impact acceptable under depletion theory)
- United States v. Brantley, 777 F.2d 159 (4th Cir. 1985) (jurisdictional element may be satisfied by intended effects)
- Powell v. United States, 693 F.3d 398 (3d Cir. 2012) (targeting theory; enterprise engaged in interstate commerce)
- United States v. Culbert, 435 U.S. 371 (1978) (acts disrupting commerce fall within Hobbs Act scope)
- United States v. Thomas, 159 F.3d 296 (7th Cir. 1998) (aggregation, act class impact on commerce)
- United States v. Wang, 222 F.3d 234 (6th Cir. 2000) (limits of Hobbs Act reach re private residences)