United States v. Taylor: Violence in Criminal Law
Introduction
The general public’s attention is focused on crimes involving violence. These atrocities are always accompanied by publicity because they entail pretty serious consequences. Violent crime in criminal legislation is defined as acts aimed at physically or mentally influencing the victim for their interests or with other motives. This paper aims to view the case United States v. Taylor, investigate it, and appraise the court’s decision.
Case Background: Justin Eugene Taylor
Justin Eugene Taylor was a marijuana dealer in Richmond, Virginia, in 2003. He intended to take money from prospective customer Martin Sylvester and his partner. The accomplice approached Sylvester in an alley, trying to rob him of cash with a semi-automatic weapon as Taylor waited nearby in an escape vehicle. When Sylvester resisted, one of the conspirators gravely wounded him. Taylor and his companion left the area without obtaining Sylvester’s money. The federal government filed a criminal complaint against Taylor six years later.
Charges and Indictments
Taylor was charged with seven counts in the government’s indictment, including conspiring to commit a Hobbs Act robbery in contravention of 18 U.S.C. 1951. In addition, he and his co-conspirator were accused of violating 18 U.S.C. 924(c) by using a firearm to advance a “crime of violence” (United States v. Taylor, n. d.). The federal authorities accused Justin Taylor of breaking the Hobbs Act when the robbery went wrong, and his accomplice wounded a man (Crimes and Criminal Procedure, 2018). The commission, attempt, or conspiracy to commit a robbery with an interstate component constitutes this act as a federal felony, as does Section 924(c), which makes it unlawful to use a firearm in connection with a “crime of violence.”
Predicate Crimes
Two violent predicate crimes were also mentioned in the indictment: a plot to commit a Hobbs Act robbery and an attempted Hobbs Act robbery. Taylor admitted to conspiring to commit Hobbs Act robbery and using a gun to promote a “crime of violence,” and the government agreed to drop the other allegations. Taylor was convicted of using a firearm to further a “crime of violence” in violation of 18 U.S.C. 924(c).
Appeal and Legal Arguments
Taylor argued in the Habeas Corpus review that the two principal offenses were not “crimes of violence” under 924(c) and urged the court to reverse his conviction and remand him in detention for a new sentencing. The U.S. Court of Appeals overturned Taylor’s conviction under 924(c) for the Fourth Circuit after finding that the Hobbs Law’s definition of attempted robbery does not always require “the use, attempted use, or threat of use of physical force” and therefore does not constitute a “crime of violence” under 924(c) (United States v. Taylor, 2022). According to the Hobbs Act, the prosecution must show that the defendant meant to finish the robbery and that they took a “significant step” to convict them of attempted robbery (Crimes and Criminal Procedure, 2018). Proof that the defendant used, attempted, or threatened to use force is not necessary for any components, even though physical force is regularly present in such cases.
Judicial Opinions and Dissent
When Taylor’s accomplice murdered a fellow drug dealer who was attempting to rob him, Judge Thomas dissented, pointing out that Taylor had officially acknowledged that he had committed a “violent crime.” When Taylor’s crime is not seen as a violent crime, Judge Thomas claims that the “categorical approach” has taken the legal system on a “journey through the looking glass” to the point of absurdity because a hypothetical defendant may have tried robbery without using force.
The Need for Clarity in Legal Definitions
Judge Thomas asserts that the Court has never adequately explained why it applied a categorical approach that put prosecutors and judges in a difficult position and forced the courts to believe that heinous crimes are not violent crimes because someone else could have committed this crime without using force. Judge Thomas contended that the court needed to reverse Davis’ ruling and use a behavioral strategy instead (United States v. Taylor, n. d.). Judge Alito also disagreed, concurring with Judge Thomas, that the categorical approach overlooks reality and leads to a dream world. Judge Alito dissented, saying that even with a categorical approach, attempted robbery under the Hobbs Law remains a severe felony. As per the judges’ decision in October 2020, Taylor was still expecting another circuit while the case was not suspended (United States v. Taylor, 2022). However, in June 2022, Taylor was free of charge, according to most opinions.
Conclusion
The court’s ruling is correct, as it entailed several circuits to prove Taylor’s involvement in the case. Instead of being a separate element that must be established in addition to the attempted offense, using force is a component of the accused’s intent. Therefore, armed violence should have served as a ground for sentencing the defendant because it can be considered an attempted threat. In addition, the fact that the case dealt with drugs should have always captured the court’s attention and enticed the government to this side of the argument. Therefore, Taylor’s attempt to involve himself in the armed robbery should have been considered a crime of violence.
References
United States v. Taylor, 136 S. Ct. 2074. (2022). Web.
Crimes and criminal procedure, 18 U.S. Code § 924 (2018). Web.
United States v. Taylor. Oyez. Web.