United States v. Taylor
View Official PDFBelow are plain-language sections to help you understand what the Court decided in United States v. Taylor and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of United States v. Taylor.
In United States v. Taylor, the Supreme Court addressed whether attempted Hobbs Act robbery qualifies as a 'crime of violence' under 18 U.S.C. § 924(c)(3)(A). The Court applied a 'categorical approach' and determined that the offense does not require proof of the use, attempted use, or threatened use of force. Consequently, the Fourth Circuit's decision to vacate Taylor's § 924(c) conviction was affirmed.
Holding
The single most important “bottom line” of what the Court decided in United States v. Taylor.
The Court held that attempted Hobbs Act robbery does not qualify as a 'crime of violence' under § 924(c)(3)(A) because it lacks an element requiring proof of force.
Constitutional Concepts
These are the Constitution-related themes that appear in United States v. Taylor. Click a concept to see other cases that involve the same idea.
-
Why Void for Vagueness is relevant to United States v. Taylor
The case involves the interpretation of the residual clause of § 924(c)(3)(B) as unconstitutionally vague, following the precedent set by United States v. Davis.
Syllabus excerpt (verbatim)In Davis, this Court held that § 924(c)(3)(B)'s residual clause was unconstitutionally vague.
-
Why Judicial Review is relevant to United States v. Taylor
The Court exercises its power to review and interpret the statutory language of § 924(c) to determine its constitutionality.
Syllabus excerpt (verbatim)The Court applies a 'categorical approach' to determine whether a federal felony may serve as a predicate for a conviction and sentence under the elements clause.
-
Why Procedural Due Process is relevant to United States v. Taylor
The case involves the requirement for the government to prove elements of a crime beyond a reasonable doubt, which is a component of procedural due process.
Syllabus excerpt (verbatim)The relevant inquiry is not how any particular defendant may commit the crime but whether the federal felony at issue always requires the government to prove—beyond a reasonable doubt, as an element of its case—the use, attempted use, or threatened use of force.
Key Quotes
Short excerpts from the syllabus in United States v. Taylor that support the summary and concepts above.
Attempted Hobbs Act robbery does not qualify as a 'crime of violence' under § 924(c)(3)(A).
The relevant inquiry is not how any particular defendant may commit the crime but whether the federal felony at issue always requires the government to prove...the use, attempted use, or threatened use of force.
The government's view of the elements clause would have it effectively replicate the work formerly performed by the residual clause.