United Statesv.Taylor
Justin Taylor participated in an attempted Hobbs Act robbery during which an accomplice shot a man. He was charged with using a firearm in connection with a crime of violence under the federal firearm statute. The Supreme Court held that attempted Hobbs Act robbery is not categorically a crime of violence under the statute’s elements clause because an attempt can be completed without the defendant using or threatening physical force. The Court rejected the Government’s argument that the completed offense’s force element automatically carries over to the attempt. The judgment of the Fourth Circuit was affirmed. Justice Thomas, joined by the Chief Justice and other Justices in relevant portions, dissented from the holding that Taylor’s offense did not qualify, arguing that the statutory elements and the attempted robbery conduct supported treating it as a crime of violence.
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