## Facts

- David Anthony Taylor participated in two home-invasion robberies in Roanoke, Virginia, targeting suspected marijuana dealers.
- In each robbery, the assailants demanded the location of drugs and money, found neither, and left with little or nothing.
- Federal prosecutors charged Taylor with two counts of Hobbs Act robbery, which requires proof the robbery “in any way or degree” affected commerce.
- At Taylor’s first trial, the jury failed to reach a verdict.
- At retrial, the district court barred Taylor from offering evidence that the dealers he targeted dealt only locally grown and sold marijuana.
- The jury convicted Taylor on both Hobbs Act counts; the district court denied Taylor’s motion for acquittal on the commerce element.
- The Fourth Circuit affirmed, holding that the government needed to show only that Taylor robbed or attempted to rob a drug dealer of drugs or drug proceeds.

## Issues

1. In a Hobbs Act robbery prosecution involving drug dealers, must the government prove a case-specific effect on interstate commerce beyond showing the defendant targeted drugs or drug proceeds?
2. Does the commerce element permit conviction where the defendant sought marijuana or its proceeds, even if the marijuana activity was allegedly intrastate?

## Decision

- The Supreme Court affirmed Taylor’s convictions.
- The Court held the Hobbs Act commerce element is satisfied if the government proves the defendant robbed or attempted to rob a drug dealer of drugs or drug proceeds.
- The government need not prove that the particular drugs or proceeds traveled in interstate commerce or that the specific robbery produced a measurable commercial effect.
- The Court concluded the district court did not err in excluding Taylor’s proposed evidence about the intrastate character of the marijuana operation.
- Justice Thomas dissented, arguing the government should be required to prove a more concrete, case-specific effect on interstate commerce.

## Legal Principles

- The Hobbs Act reaches robberies with any effect on commerce within Congress’s Commerce Clause power.
- Congress may regulate local economic activity that is part of a broader class of activities with a substantial aggregate effect on interstate commerce.
- Drug production, possession, and distribution constitute an economic class of activities within federal regulatory power; robberies aimed at drugs or drug proceeds affect commerce within that jurisdiction.
- In this setting, the commerce element’s legal meaning is fixed as a matter of law; the prosecution’s factual burden is to prove beyond a reasonable doubt that the defendant’s conduct fell within the regulated class (robbery or attempted robbery of a drug dealer for drugs or proceeds).

## Conclusion

Taylor holds that, for Hobbs Act prosecutions involving robberies of drug dealers, the interstate-commerce element is established by proving the defendant targeted drugs or drug proceeds, without additional proof that the particular offense affected interstate commerce in a case-specific way.


Taylor v. United States, 579 U.S. 301 (2016)