U.S. Supreme Court Upholds Conviction of Defendant Prosecuted Under the Hobbs Act
There has been growing bipartisan support for criminal justice reforms. However, the recent Supreme Court ruling of Taylor v. United States could potentially affect these efforts while raising the issue of federalism in the process.
The central issue raised by the defendant in Taylor was the Hobbs Act, a 1946 federal law criminalizing robberies and attempted robberies “affecting interstate commerce in any way or degree.” Over time, the constitutional interpretation of “interstate commerce” has grown, allowing more and more of the economy to be open to federal regulation. In 2005, the Supreme Court upheld the Controlled Substances Act, allowing intrastate illegal drug markets to fall under federal jurisdiction through the Commerce Clause, thus giving rise to the defendant’s challenge to the Hobbs Act.
Anthony Taylor, the defendant, was convicted under the Hobbs Act for two separate robberies of Virginia marijuana dealers, where he stole $40, three cell phones, some jewelry, and a marijuana cigarette. Taylor was a member of a gang that targeted drug dealers for crimes of robbery because of their disincentive to report these crimes. Due to the size of the gang, who referred to themselves as the “Southwest Goonz,” the government argued that they had the potential to significantly impact interstate commerce.
However, Taylor’s attorney argued that the government did not meet its burden of preponderance of evidence that the robbery that Taylor committed in and of itself affected interstate commerce. The crimes committed by the Southwest Goonz were violent and in at least one instance; Taylor threatened one of the house’s occupants with a gun during commission of the robbery. If Taylor would have been tried in a Virginia state court, he could have faced at least one count of burglary while armed with a deadly weapon, which is punishable by 20 years to life in prison.
Under federal sentencing laws, Taylor faced a maximum sentence of life in prison on the gun charge, and up to 20 years for each violation of the Hobbs Act. Unlike state law, he must serve a minimum of 85 percent of his sentence even with credit for good behavior. Though the sentencing guidelines are similar in both state and federal jurisdictions, robberies such as these have historically been prosecuted in state courts. However, the broad interpretation of the Hobbs Act allowed for this case to be prosecuted in federal court.
Justice Clarence Thomas, lone dissenter in Taylor v. U.S., argues the Court “fails to identify language in the Hobbs Act that conveys clearly Congress’ intention to reach the sorts of local, small-scale robberies that States traditionally prosecute.” Thomas argues the burden of proof placed on the government is too low, as precedent defines “interstate commerce” to mean that Congress can regulate “those activities having substantial relation to interstate commerce.” This allows for the Hobbs Act to punish robberies that have not been proven “beyond a reasonable doubt that the defendant’s robbery itself affected interstate commerce.” While Taylor’s deplorable and heinous criminal conduct and commission of numerous violent crimes clearly merits a long prison term, Taylor v. U.S. sets a precedent of potentially increasing federal jurisdiction at the expense of a state’s jurisdiction, which could violate federalism principles.