## Facts

- Carlos Flores-Rodríguez owned and operated a Texaco gas station in Juana Díaz, Puerto Rico, as a sole proprietor.
- In the two months before the offense, the station purchased approximately 40,000 gallons of gasoline from a refinery in the United States Virgin Islands.
- An employee routinely delivered the station’s daily receipts to Flores’s home; the night before the crime, about $600 in receipts was placed in a kitchen cabinet.
- Héctor Jiménez-Torres joined five others in a plan to rob Flores at his residence; the group traveled to the home in the early morning, armed with two guns.
- During the home invasion, two conspirators took Flores downstairs while Jiménez-Torres stayed upstairs with Flores’s wife.
- Jiménez-Torres heard gunshots; a conspirator shot Flores, who later died, and the group stole the cash from the kitchen cabinet.
- The gas station closed permanently the next day.

## Issues

1. Whether the evidence was sufficient to prove the Hobbs Act interstate-commerce element where the robbery occurred at the owner’s home but targeted business receipts and was followed by the gas station’s closure.
2. Whether the evidence was sufficient for a rational jury to find that Jiménez-Torres knowingly participated in a robbery (as opposed to some lesser or different offense), despite his limited physical role during the invasion.
3. Whether the district court impermissibly delegated judicial authority by allowing the probation officer to determine details of drug testing and treatment during supervised release.

## Decision

- The First Circuit affirmed the convictions and sentence.
- It held the Hobbs Act commerce element was satisfied under a minimal-effects standard because the stolen property was business operating funds and the business closed immediately afterward.
- It held the evidence permitted a finding beyond a reasonable doubt that Jiménez-Torres knowingly joined and participated in the robbery plan, notwithstanding that he remained upstairs during part of the offense.
- It upheld the supervised-release condition, concluding the court imposed the condition and permissibly left implementation details (testing/treatment specifics) to the probation officer.

## Legal Principles

- Under the Hobbs Act, the interstate-commerce element is satisfied by a minimal effect on commerce; the effect may be shown through interference with a business engaged in interstate commerce.
- A robbery of an individual at a private residence may satisfy the Hobbs Act where the target and proceeds are business assets (e.g., daily receipts) and the offense disrupts the business’s operations.
- In reviewing sufficiency challenges, the evidence is viewed in the light most favorable to the verdict, and the conviction stands if a rational jury could find the elements proved beyond a reasonable doubt.
- A defendant may be found to have knowingly participated in a robbery based on coordinated planning, armed entry, presence, and conduct during the offense, even without personally taking property or firing the fatal shot.
- A sentencing court may delegate to probation officers the administrative details of implementing supervised-release conditions, so long as the court itself imposes the substantive condition.

## Conclusion

The First Circuit sustained Hobbs Act and § 924(j) convictions arising from an armed home-invasion robbery of a gas-station owner, holding that theft of business receipts and the station’s immediate permanent closure established the required effect on interstate commerce, that the evidence supported the defendant’s knowing participation in the robbery, and that delegating drug-testing and treatment logistics to probation was permissible.


United States v. Jiménez-Torres, 435 F.3d 3 (1st Cir. 2006)