United States v. Leon Eckford, 77 F.4th 1228

Between late 2015 and early 2016 Eckford participated in two armed jewelry-store robberies, one in which co-conspirators used a handgun against a security guard; total theft exceeded $2 million.
Eckford was arrested, admitted participation, and pleaded guilty to conspiracy to commit Hobbs Act robbery, two counts of aiding and abetting Hobbs Act robbery, and aiding and abetting use of a firearm in a crime of violence under 18 U.S.C. § 924(c).
The district court calculated guidelines for the Hobbs Act counts and added a consecutive mandatory minimum under § 924(c)(1)(A)(ii) for brandishing a firearm, then varied downward to impose a 132-month sentence.
On appeal Eckford argued (1) Hobbs Act robbery is not a "crime of violence" under § 924(c)’s elements clause and (2) aiding and abetting Hobbs Act robbery cannot serve as a predicate for § 924(c) liability.
The Ninth Circuit reviewed the issues de novo and affirmed: Hobbs Act robbery is a crime of violence under the elements clause, and aiding and abetting such robbery likewise qualifies.

Issue	Eckford's Argument	Government's Argument	Held
Standard of review	He preserved the claim; if not, plain error applies	Govt: claim not preserved; plain error review	Court chose to review de novo as pure legal question and no prejudice to govt
Is Hobbs Act robbery a "crime of violence" under § 924(c)(3)(A)?	Hobbs Act can be committed by threats to intangible economic interests that do not involve "physical force"	Hobbs Act robbery necessarily involves threats or use of violent physical force; Dominguez II controls	Affirmed: completed Hobbs Act robbery is categorically a crime of violence under the elements clause
Does aiding and abetting Hobbs Act robbery qualify as a "crime of violence"?	Aider may be complicit without personally using or threatening force, so aiding cannot satisfy elements clause	Aiding and abetting is not a separate offense; accomplices are punished as principals and thus satisfy the elements clause	Affirmed: aiding and abetting a crime of violence is itself a crime of violence for § 924(c) purposes

Johnson v. United States, 559 U.S. 133 (2010) ("physical force" means violent force capable of causing pain or injury)
United States v. Taylor, 142 S. Ct. 2015 (2022) (attempted Hobbs Act robbery does not categorically require use or threat of physical force)
Dominguez v. United States, 48 F.4th 1040 (9th Cir. 2022) (panel reinstating that completed Hobbs Act robbery is a crime of violence)
Dominguez v. United States, 954 F.3d 1251 (9th Cir. 2020) (earlier panel opinion reasoning Hobbs Act robbery requires at least implicit threat of violent force)
United States v. Davis, 139 S. Ct. 2319 (2019) (struck down § 924(c)(3)(B) residual clause as unconstitutionally vague)
Duenas-Alvarez v. United States, 549 U.S. 183 (2007) ("realistic probability" test for comparing state statutes to federal generic crime)
Rosemond v. United States, 572 U.S. 65 (2014) (accomplice liability principles and mens rea for aiding and abetting)
Young v. United States, 22 F.4th 1115 (9th Cir. 2022) (aiding and abetting a crime of violence is itself a crime of violence)
Mathis v. United States, 932 F.3d 242 (4th Cir. 2019) (discussion that "property" in Hobbs Act encompasses threats involving force against property)