Taylor v. United States

The prosecution in a Hobbs Act case satisfies the Act’s commerce element when it proves that the defendant robbed or attempted to rob a drug dealer of drugs or drug proceeds.

Petitioner was indicted under the Hobbs Act, for attempting to rob marijuana dealers of their drugs and money. The Hobbs Act criminalizes robberies and attempted robberies that affect commerce “over which the United States has jurisdiction.” The District Court found Petitioner guilty and the Fourth Circuit affirmed, holding that drug dealing in the aggregate affects interstate commerce. The Supreme Court granted certiorari to determine what the Government must prove to satisfy the Hobbs Act’s commerce element when theft of drugs or drug proceeds is involved. Turning to Commerce Clause precedent, the Supreme Court reaffirmed that Congress may regulate local activities that substantially affect interstate commerce in the aggregate. In Gonzales v. Raich, the Court held that intrastate production, possession, and distribution of controlled substances, particularly marijuana, constitutes activity that substantially affect interstate commerce. Therefore, the marijuana market is commerce that the United States has jurisdiction over. It follows that a person who affects the intrastate sale of marijuana through robbery or attempted robbery affects commerce over which the United States has jurisdiction and is guilty under the Hobbs Act. AFFIRMED.